The two-pillar package provides for the standstill and rollback of unilateral measures, such as digital services taxes (DSTs). Countries have experimented with these taxes as an alternative to a global solution agreed by all members, but always as a second-best approach. Inclusive Framework member...
While the Pillar 1 approach is still to be agreed by the Inclusive Framework, local applications including the UK’s digital services tax will remain. It is anticipated that these unilateral measures will be repealed as part of any future Pillar 1 agreement. The current proposed ap...
On 13 February 2020, the OECD presenteda number of preliminary, high-level results on the economic and impactassessment analysis undertaken with respect to the implementation of thetwo-pillar approach towards addressing the tax challenges of the digitaleconomy (for further details on the two-pillar ...
3跨国企业如果在居住国有销售经营活动,则居住国也应当按公式分得一部分金额A。 4 OECD. Statement by the OECD/G20 Inclusive Framework on BEPS on the Two-Pillar Approach to Address the Tax Challenges Arising from the Digitalization of the Economy[R]. Paris: OECD, 2020. 文章来源:国际税收...
Chinese technology titans, such as Alibaba and Tencent, which have divisions in the Cayman Islands, could also be hit by the two-pillar approach. MNEs should carefully review the principal design elements agreed to in the OECD statement to determine how the proposals would impa...
1 Report, but a lack of consensus prevented countries from taking action. In light of increasing public pressure,the G20 delivered a mandate in 2017 to the OECD/G20 to renew work on this issue. Since early 2019, the OECD/G20 Inclusive Framework has been developing a Two-Pillar approach:...
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...
approach for calculating the Pillar Two reallocation of associated deferred tax amounts of a parent to its CFC. Several numerical examples are given that illustrate the interaction with deferred tax from credits for the underlying tax of the CFC itself, requirements to recast deferred tax amounts ...
approaches to dispute prevention and resolution. Any such processes will need to be legally binding on countries via an internationally agreed legal instrument to have effect. One approach would be via a double tax treaty “wrapper” for Pillar Two to support the rules implemented domestically by ...
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