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...
In its press release the OECD notes that the Commentary (to be published in early 2022) will address co-existence of Pillar Two and United States (US) Global Intangible Low-Taxed Income (GILTI) rules. Recent legislative developments in the US where the Build Back Better bill, among other th...
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 OECD inclusive framework will continue to publish administrative guidance on further Pillar Two topics, including, for example, the deferred tax liability recapture rules and deferred tax arising in relation to the profits of other constituent entities such as CFCs or permanent establishments. More ...
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...
1.How would the two-pillar package make sure that MNEs pay their fair share of tax? 1. 双支柱方案将如何确保跨国公司缴纳公平份额的税款 The package has two pillars, and each one addresses a different gap in the existing rules that allow MNEs to avoid paying taxes. First, Pillar One applies...
Rules, an area under consideration by the Inclusive Framework but on which consensus has not been reached.7 In addition, with respect to the other core element of Pillar Two — the Subject to Tax Rule (STTR) — the OECD has released a model treaty provision together with an accompanying ...
OECD TWO-PILLAR GLOBE RULES: IS IT TIME TO ABANDON HOPE FOR INTERNATIONAL COOPERATION ON A GLOBAL MINIMUM CORPORATE INCOME TAX?VANDERMEULEN, WILLEMEmory International Law Review
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/...
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. ...