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 implementatio...
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 ...
OECD Pillar Two: Information return and safe harbors published 2022年8月18日 香港推迟实施支柱二 Hong Kong defers the implementation of Pillar Two
1.How would the two-pillar package make sure that MNEs pay their fair share of tax?1. 双支柱...
Specifically, they agreed to: (1) collaborate on projects to utilize new technology to enable further digital transformation of tax administration; (2) work together on the consistent, effective implementation of Pillar Two; and (3) enhance the effectiveness and reach of its global capacity buildi...
The OECD’s Pillar Two introduces complex challenges for multinational groups. Streamline Pillar Two adoption with PwC’s tech-enabled approach.
Step 2: Select a topic.The last topic in the dropdown list includes PwC thought leadership publications related to the OECD Model Rules, the EU Minimum Tax Directive, or the implementation of Pillar Two in the specific country, depending on the selection made in Step 1. ...
tax challenges arising from digitalisation and globalisation of the economy,work on the implementation of the two-pillar plan is well under way. As part ofthis next phase, the Inclusive Framework will consult stakeholders on a numberof aspects of Pillar One and Pillar Two over the coming months...
of Pillar Two — the Subject to Tax Rule (STTR) — the OECD has released a model treaty provision together with an accompanying commentary,8 as well as documents with respect to a multilateral instrument that jurisdictions can use to facilitate implementation of the STTR into their tax treaties...
20, 2021. In December 2022, the European Commission finalized a directive on Pillar Two implementation with unanimous agreement from EU member states, requiring each to transpose key aspects into domestic law by Dec. 31, 2023. The OECD secretary-general previously acknowledged in May 2022 that ...