“top-up tax” liabilities. Many countries are legislating these rules into local law, effective in 2024. MNEs should act now to assess the impact of these new rules and local laws. Importantly, the new tax framework may impact even MNEs with effective tax rates above the 15% m...
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In fact, under the GloBE rules, in certain situations, a jurisdiction that incurs a GloBE loss and pays no corporate income tax can still incur GloBE top-up tax liability. MNEs should carefully analyze jurisdictions with unrecognized deferred tax positions (or valuation allowances) to ensure ...