Within Pillar Two projects, one of the biggest challenges is the knowledge of the Pillar Two rules by both the tax and accounting departments - either at the beginning of the project or when rolling out the project. Top-up tax can be levied either at the level of the so-called "Ultimate...
The Pillar Two global minimum tax rules incorporate an agreed rule order, which prevents a jurisdiction from levying top-up tax in respect of low tax profits where those profits have already been subject to top-up tax under "qualified" rules in another jurisdiction. A separatequestions and answ...
The model rules also allow for countries to introduce a qualified domestic minimum top-up tax (QDMTT) aligned with Pillar Two. Under a QDMTT, top-up taxes in respect of any low-taxed profits of a group’s entities in that country are payable domestically, rather than to other countries u...
Data is perhaps the most complex component of Pillar Two compliance. Not only must companies have access to consistent data in order to calculate their tax burden under the new rules, but they must also adapt their internal processes, controls, and systems to gather and report data even as th...
(i.e. one conformant to the GloBE rules design), it will pay the IIR tax in respect of the Top-Up Tax of a low-taxed constituent entity, rather than an intermediate parent entity. Where the Ultimate Parent Entity is not subject to a qualified IIR, IIR taxing rights will ‘drop’ ...
In an astonishing development, the model rules created a third alternative—the QDMTT. Under this new rule, low-taxed countries—the countries that have long helped large corporations avoid tax—are now first in line to charge the top-up tax on low-taxed income of entities in that country....
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.
The basic rule is the top-up tax to be collected in the country of the ultimate parent company of the MNE, if this country has introduced the GloBE rules. If not the case, the top-up tax can be collected from the lower parent company that is next in the ownership structure of the ...
Pillar Two global minimum tax rules are changing the taxation landscape. How can Thai multinationals prepare for compliance? Listen to find out what actions can be taken to be better equipped for the impact. Uncovering why most Thai banks fall short of digitalisation goals What a...