On December 20, 2021 the OECD published the Global Anti-Base Erosion (‘GloBE’) Model Rules, also known as Pillar 2. These Model Rules form part of the so-called BEPS 2.0 Project and provide governments with a template for implementing the Pillar 2 agreement that was reached in October 20...
The GloBE rules are part of Pillar 2, which provide for a coordinated system of taxation intended to ensure large multinational enterprise groups pay a minimum level of tax on the income arising in each of the jurisdictions where they operate. We note that the Commentary to the GloBE Rules ...
Close to 140 countriesagreedto the October 2021 framework, but not to these new model rules. The changes introduce even more uncertainty and complexity to Pillar Two. In addition, the new UTPR may violate many bilateral tax treaties. Pillar Two is starting to look more like a train wreck th...
Further to the publication of the G20/OECD inclusive framework on BEPS’ Global Anti-Base Erosion Model Rules (Pillar Two) designed to ensure a global minimum level of taxation for multinational groups
23 May 2023International Tax Reform — Pillar Two Model Rules (Amendments to IAS 12)issuedAn entity applies the exception and the requirement to disclose that it has applied the exception immediately upon issuance of the amendments;the remaining disclosure re...
Required count rules/queries to be saved somewhere. A way to execute the new count. This could be as simple as adding the eloquent count/sum after every bit of code that updates that table, but I feel there must be a better way. Would a model observer be a good use for this? Is ...
Rules of creep decay time After instantaneous compaction of rock, mudstone enters the stage of decay creep, in which the creep rate of rock decreases with time. When the creep rate decreases to a steady state, the decay creep stage ends. The time is the decay creep time. The creep decay...
To ensure safe production, many rules and regulations, such as the Coal Mine Safety Rules (Version 2022) and the Detailed Rules for Mine Water Prevention and Control (Version 2018), have been enacted. Mining predecessors have detailed a series of technical procedures for the prevention and ...
This research attempts to develop a visco-hyperelastic constitutive model and applies it to characterize the uniaxial and biaxial stress-softening behavior of EPDM rubber, which has great potential in pillar industries of national production. The proposed model is constructed by combining a hyper-elastic...
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