The possibility for governments to grants tax incentives is likely to be affected by the upcoming Pillar 2 regulations, which are going to be implemented in the form of GloBE Rules into domestic tax laws. Specific rules address the use of tax credits providing for a specific treatment which ...
GloBE收入包括四年内可退还的税收抵免(Qualified refundable tax credits, QRTC),而不符合此要求的税收抵免不包括在内。国际航运收入也不包括在GloBE方案内。进一步的细节和规则载于经合组织示范规则第3章。 经合组织示范规则第4章提供了全球收入应缴税款的计算方法。涉及的税收包括所有所得税,包括为财务报表目的而...
”“marketable transferable tax credits,” and “qualified flow through tax benefits,” and the requirement that Pillar Two calculations should generally be prepared using the presentational currency of the ultimate parent entity’s consolidated financial statements....
a corresponding carry forward of excess foreign tax credits. This mechanism is extended to situations involving permanent establishments, hybrid entities and reverse hybrid entities, and also to similar situations involving the interaction of domestic tax losses brought forward and foreign tax credits. ...
The Model Rules include details about when “refundable” tax credits should be treated as income or a reduction in tax liability for purposes of the GloBE rules. In particular, “Qualified Refundable Tax Credits” are treated as income (with the result that the tax offset by the credits is ...
Poland publishes draft legislation implementing global minimum tax (Pillar Two), with option to apply retroactively from 1 January 2024.
taxed income (GILTI) to be considered compliant with Pillar Two, it is uncertain whether the U.S. will grant foreign tax credits. If not, the result is double taxation: The low-taxed income is taxed to the UPE under GILTI and to the foreign subsidiary under QDMTT, with no relief ...
Reach of the Subject to Tax Rule (STTR) Coordination and dispute management Facebook Twitter LinkedIn 15 Jan 2022 ondemand_videoWebcast CPEcredits: 0.0 Webcast FAQ scheduleTime 18:00 - 19:30your local time Watch On Demand 10 Aug 2023
2. Treatment of Qualified Flow-through Tax Benefits of Qualified Ownership Interests The guidance sets out a special rule for certain tax credits in the context of equity method investments, by introducing the new concept of Qualified Flow-through Tax Benefits. When an owner is subject to an ...
In July 2023, the OECD published additional Administrative Guidance (July Guidance) which covered topics relating to currency conversion rules when calculating Global Anti-Base Erosion (GloBE) income, tax credits taken into account, and the Substance-based Income Exclusion (SBIE). The July Guidance ...