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
Pillar 2 is designed to establish a global minimum tax (GMT) of15% on the income of MNEswith a global turnover of at least €750 million. The GMT consists of the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR). ...
will result in “top-up” tax amounts to bring the overall tax on profits in each jurisdiction where a group operates up to a minimum effective tax rate of 15%. The key components of the model rules are: qualified
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 whe...
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...
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
In 2024, the Organisation for Economic Co-operation and Development’s (OECD) Pillar Two tax regime will go into effect, instituting a global minimum tax of 15% on the profits of multinational corporations that generate more than €750 million in revenue in each jurisdiction in which they oper...
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/...