Pillar Two is a revolutionary tax system that will apply with uniform effect worldwide. It is designed to ensure that multinational enterprises pay a minimum tax of 15 % on the local income arising in each jurisdiction where they operate. What is this about and who is affected? Global min...
will result in "top-up" tax amounts to bring the overall tax on profits in each jurisdiction where a group operates up to a 15% minimum effective tax rate. The key components are: qualified domestic minimum top-up
This paper provides a high-level overview of the pillar two global minimum tax in terms of its policy objectives, technical design, and implications for Canada. After teasing out some significant known and unknown challenges, the paper offers some thoughts on whet...
tax due is (in most cases) calculated and paid by the ultimate parent entity to the tax authority in its country. The tax due is the “top-up” amount needed to bring the overall tax on the profits in each country where the group operates up to the minimum effective tax rate of 15%...
来源:https://www.oecd.org/tax/beps/pillar-two-model-rules-in-a-nutshell.pdf 第一步:范围界定: 1、确定单位内的跨国公司集团; 2、确定组成实体; 3、删除任何排除的实体; 4、确定每个组成实体的位置。 支柱二是基于国际集团公司的合并财务报表。对于合并的范围,完全合并公司及可接受特殊原因的未合并公司都...
Further to the publication of the G20/OECD inclusive framework on BEPS’ Global Anti-Base Erosion Model Rules (Pillar Two) designed to ensure a global minimum level of taxation for multinational groups
Poland publishes draft legislation implementing global minimum tax (Pillar Two), with option to apply retroactively from 1 January 2024.
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...
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...
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...