全球最低税（Global Minimum Tax，GMT）概念，缘于2019年10月OECD发表的“双支柱”（Two—Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy，即“支柱二”）政策说明。支柱二提出的全球最低税改革方案，引起各国强烈反响。2021年12月，欧盟委员会发布《实施全球最低公司税...
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 OECD inclusive framework continues to publish guidance on the interpretation and application of aspects of the Pillar Two global minimum tax rules, with a view to enabling their consistent application and to provide simplifications where possible. The third tranche of administrative guidance focuses ...
The Pillar Two global minimum tax rules incorporate an agreed rule order, which prevents a jurisdiction from levying top-up tax in respect of low tax profits where those profits have already been subject to top-up tax under "qualified" rules in another jurisdiction. A separatequestions and answ...
Tax on Multinational Enterprises(“the Law”). This release is a further demonstration of global alignment and commitment to the Organization for Economic Cooperation and Developments (‘‘OECD’’) inclusive framework (‘‘IF’’) to introduce a global minimum tax (“GMT”) of 15% on large ...
A 15%+ financial statement effective tax rate may not be enough to avoid global minimum tax as part of BEPS 2.0 Pillar Two. Learn more.
Pillar Two hasn’t been adopted in Thailand yet, but some countries have already enacted global minimum tax legislation and others plan to enact legislation soon. How can Thai multinational enterprises prepare for compliance? Are there measures available to mitigate the impact? What o...
This memorandum provides a general overview of the Pillar 2 provisions. A more in-depth analysis authored by KPMG International member firms will follow shortly. Scope of Global Minimum Tax rules General In general, the GloBE rules apply for a multinational enterprise where the consolidated MNE Gro...
BEPS Pillar 2 101: Exploring the OECD’s pillar 2 global minimum tax impact on tax incentives This article will explore how the global minimum tax affects tax incentives and what you need to do to minimize negative impacts. Learn More
The Pillar 2 Global Anti-Base Erosion (GloBE) rules have been developed by the Organisation for Economic Co-operation and Development (OECD) to provide a common system of taxation that ensures multinational enterprises (MNEs) pay a global minimum tax (GMT) of 15% in each jurisdiction where the...