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 ...
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/...
Pillar Two Data Input Catalog March 2024 https://www.pwc.com/gx/en/services/tax/pillar-two-readiness.html PwC's Pillar Two Data Input Catalog March 2024 1 Executive summary In December 2023, the OECD published its most recent set of Administrative Guidance (December Guidance) on the Global ...
Implementation of additional OECD Guidance According to the MTA 2024 explanatory memorandum, the OECD Pillar 2 Model Rules, its related Commentary, and the OECD Administrative Guidance serve as interpretation aids for the MTA 2024. Accordingly, the Proposals are designed to implement in the MTA 2024...
In the current process of elaborating an international effective minimum tax regime (Pillar Two proposal of the OECD/G20 Inclusive Framework), simplification meDllefeld, CedricEnglisch, JoachimHarst, SimonSchanz, DeborahSiegel, FelixSocial Science Electronic Publishing...
The OECD published Tax Challenges Arising From the Digitalisation of the Economy — Global Anti-Base Erosion Model Rules (Pillar Two)1 in December 2021 and subsequently issued additional commentary and administrative guidance2 clarifying several aspects of the model rules (collect...
The June 2024 Administrative Guidance further specifies that Articles 3.2.3, 6.2.2 and 6.3.1 through Article 6.3.4 of the GloBE Model Rules should only apply to Constituent Entities in the Transition Year (i.e., first Fiscal Year that the MNE Group comes within the scope of the GloBE Rule...
其中第3(1)款规定，除上下文另有要求外，本法的某些部分（包括实施IIR和UTPR的部分，但不包括实施QDMTT的部分）应与经济合作与发展组织（以下简称为“经合组织”或“OECD”）全球反税基侵蚀（GloBE）立法模板(Model Rules)、注释（Commentary）和征管指南（Administrative Guidance）的规定保持一致，这些规则可能会不时...
Based on the latestAdministrative Guidance, an election should be available for an entity to optionally include income from distributions after that first year in its GloBE ETR computations, which could be interesting if such income is high-taxed and would help shelter low-taxed income under the ...