The guidance includes a permanent simplified calculation safe harbor for non-material constituent entities (NMCEs). Broadly, an NMCE is an entity that is not consolidated in the ultimate parent entity’s consolidated financial statements solely on size or materiality grounds but is still considered a...
Businesses will need to work through the new guidance with reference to their facts and group entities to ensure that the effect of the new guidance is understood and reflected in calculations. Of particular note is the requirement for additional deferred tax to be calculated on differences between...
On December 20, 2022, the OECD released new guidance and public consultation documents on three topics in its continued effort to have the first elements of Pillar 2 in effect as of January 1, 2024. These documents are not the highly anticipated impleme...
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进行修改。
Originality/value - This paper reviews the PRA-prescribed methodologies and the Pillar 2 regulatory guidance for calculating the capital add-on for the single name, sector and geographical credit concentration risk. In doing so, this paper becomes the first to test the assumptions that the ...
the UAE DMTT was not included in the Central Record of Pillar 2 Legislation with Transitional Qualified Status. Therefore, it is still unclear if the UAE’s DMTT will receive Qualified Status. However, based on our understanding that these rules align with the OECD Guidance, we would expect ...
Pillar II: Was bei Vermögensübertragungen zu beachten ist Pillar II: Bei Vermögensübertragungen müssen Unternehmen mit einer zukünftigen Mindestbesteuerung rechnen. Was es zu beachten gilt, erfahren Sie hier. 19 Dez. 2022Martin Ellerbusch+ 2...
Strong Financial and Analytical Acumen: Ability to manage complex accounting / tax calculation models, interpret large sets of financial data, and provide clear guidance on compliance strategies Collaborative Approach: Experience working across multiple regions and organisational functions, with strong interper...
11:10 – Can future OECD administrative guidance be introduced retroactively in the UK? 13:20 – What is the status of the undertaxed profits rule in the UK? 15:10 – How does the UK determine that another country’s Pillar Two regime is qualified? 16:50 – What is the status of...
The document aims to provide tax administrations and taxpayers with guidance on the common interpretation and application of the GloBE Rules. Please follow the link below to access the Consolidated Commentary: https://www.oecd.org/publications/tax-challenges-arising-from-the-digitalisation-of-the-econo...