On 17 June 2024, theOECD/G20 Inclusive Framework on BEPS(“OECD inclusive framework”) published further administrativeguidanceon the implementation of the Pillar Two global minimum tax rules ("Pillar Two"), together with details of the processes for determining that jurisdictions' local implementation...
Administrative guidance was released in February 2023 on allocating blended CFC taxes (such as US GILTI (global intangible low-taxed income)) to group entities for the purposes of the Pillar Two calculations using a formulaic approach based on “blended CFC allocation keys.” Further guidance has ...
1. 关于支柱2下GloBE规则的第三批行政指南: https://www.oecd.org/tax/beps/administrative-guidance-global-anti-base-erosion-rules-pillar-two-december-2023.pdfwww.oecd.org/tax/beps/administrative-guidance-global-anti-base-erosion-rules-pillar-two-december-2023.pdf 2. 更新支柱1下关于金额A多边公...
The two-pillar package will need to be finalised in October 2021 and then implemented and this requires more work to address the outstanding points and in developing model legislation, a multilateral instrument and implementation guidance. The Inclusive Framework intends to complete this work in 2022...
Since that agreement was reached, the Inclusive Framework has released a series of significant agreed documents on the global minimum tax under Pillar Two, including the GloBE Model Rules,2 Commentary to the GloBE Model Rules,3 guidance on GloBE Safe Harbors,4 three packages of GloBE Administrative...
In March 2022, the OECD released technical guidance on its 15% global minimum tax agreed as the second ‘pillar’ of a project to address the tax challenges arising from digitalisation of the economy. This guidance elaborates on the application ...
In the article, Charlotte and Christy delve into each document's topic and why it matters, such as the administrative guidance's coverage of deferred tax liability recapture and the treatment of securitization vehicles, as well as country-by-country reporting requirements and the Pillar Two framewor...
Summary of OECD Pillar 2 Guidance The documents released on December 20, 2022 are: Guidance on Safe Harbors and Penalty Relief A public consultation document on the GloBE Information Return and A public consultation document on Tax Certainty for the Glo...
Pillar 2 implementing EU Directive on December 22, 2021. The OECD is set to provide more guidance in the form of a Commentary and a Pillar 2 implementation framework during the course of 2022 and, moreover, publish a model provision for a Subject to Tax Rule together with a multilateral ...
Tax Policy Alert OECD releases Administrative Guidance on the Pillar Two Global Minimum Tax Rules 7 February 2023 In brief The OECD released Administrative Guidance ('guidance') on the Pillar Two Global Anti-Base Erosion Rules (GloBE Rules) on 2 February. The guidance was approved by the OECD/...