The OECD inclusive framework’s Pillar Two model rules, applicable to large multinational groups with annual consolidated group revenue of at least EUR 750 million, will result in “top-up” tax amounts to bring the overall tax on profits in each jurisdiction where a group operates up to a m...
Further guidance has been provided on the meaning of revenue for the EUR 750 million consolidated revenue threshold. Revenue includes the inflow of economic benefits from the group’s ordinary activities reflected in the profit and loss statement of the ultimate parent entity’s consolidated financial ...
In December 2021, the OECD published model rules to assist in the domestic implementation of the Pillar 2 minimum global tax rate of 15% for multinational groups with a consolidated revenue of EUR 750 million or more. Since then, the OECD has published further administrative guidance on the app...
Pillar 2 is one of two pillars of the OECD/G20 Inclusive Framework's plan to reform international taxation. With139 member countries, Pillar 2 is designed to establish a global minimum tax (GMT) of15% on the income of MNEswith a global turnover of at least €750 million. The...
Global minimum taxation affects multinational enterprises with a minimum turnover of EUR 750 million. According to OECD estimates, this means that around 8.000 enterprises worldwide (including around 800 in Germany) will be subject to this tax. The intention of Pillar Two is to ensure that the ...
The GloBE Rules aim to impose a global minimum tax of 15% on multinational enterprises with a revenue in excess of EUR 750 million. In doing so, the effective tax rate has to be calculated in the jurisdiction where a multinational enterprise has a taxable presence. The starting point for ca...
In scenario 2, global minimum taxation only applies on the seller's side. There are potential risks if the revenue threshold of 鈧 750 million is not met or if the acquiring group "grows into" the minimum taxation through the transaction. The text describes various...
In 2024, the Organisation for Economic Co-operation and Development’s (OECD) Pillar Two tax regime will go into effect, instituting a global minimum tax of 15% on the profits of multinational corporations that generate more than €750 million in revenue in each jurisdiction in which they oper...
• in at least two of the four years immediately preceding the tested fiscal year, • has an annual income of at least 750 million euros in the consolidated financial statements of the ultimate parent company. Based on these rules, a MNE will have to pay top-up corporate income tax for...
to apply the HKMTT to both Hong Kong and foreign-headquartered groups applying the annual consolidated revenue threshold as under the GloBE Rules (i.e. EUR 750 million or more); the HKMTT will be imposed on100%of the total top-up tax computed for all the Hong Kong cons...