What's the Outlook on Tax Certainty for MNEs Subject to Amount A?

Readers who follow international tax developments will be familiar with the political dynamic that led to last year's unprecedented agreement among 137 countries on the so-called two-pillar solution regarding taxation of business profits of multinational enterprises (MNEs). Numerous countries' piecemeal adoption of digital services taxes and other unilateral tax measures aimed at nonresident MNEs provoked retaliatory action by the US in the form of tariffs, or the threat of tariffs, on a wide range of exports to the US from those countries.