The qualifying income or loss for each constituent entity is then determined based on the profit or loss for the year in accordance with the consolidated accounting standard, making Pillar Two-specific adjustments. In the third step, the "covered taxes" of each constituent entity are determined, ...
Longview Pillar 2 Series: Data Allocation, GloBE Income & Covered Taxes Across Different Entities On-Demand Webinar Longview Pillar 2 Series: Uncertain Tax PositionsThe Role of Technology in Adopting BEPS 2.0 BEPS 2.0 will introduce new complexities into the tax forecasting and reporting processes,...
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 ...
Expanded guidance is provided on the principles relevant to allocating deferred taxes between group entities where a deferred tax balance in the financial accounts of one entity arises due to the income of a different Pillar Two entity. The guidance focuses on deferred tax associated with CFC rules...
Following the 2023 Budget when Singapore first stated its intention to introduce Pillar Two top-up taxes, the Finance Minister has announced that Singapore will proceed to implement two components of Pillar Two – the Income Inclusion Rule (IIR) and Domestic Top-up Tax (DTT) - for in-scope ...
The financial accounting net income and taxes of the target entity are considered for the year in which it joins or leaves the group. For subsequent years, the entity’s Pillar 2 Income or Loss and Adjusted Covered Taxes are determined based on the historical carrying value of assets and liab...
On the technological side, Pepper explains, many companies will need to invest in upgrades to their enterprise resource planning (ERP) systems to get the data they need. On top of this, “people will need some kind of Pillar Two calculation engine that takes your income and taxes and tells...
all industries, particularly in service delivery and online retail. Individual countries have introduced a range of new tax laws in the interim, addressing trading entities involved in online sales or platforms. These companies are subject to new digital service taxes, which previously did not exist...
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. ...
and challenges tax departments say they will face over the next three to five years. They will need accurate, timely tax-related data that is integrated across their organization, whether to comply with Pillar Two, calculate their global tax liability, or assess indirect taxes owed in ...