The OECD model rules also allow for countries to introduce a qualified domestic minimum top-up tax (QDMTT) aligned with Pillar Two. Top-up taxes in respect of any low-taxed profits of a group’s entities in that country would then be paid to the local tax authority, rather than to othe...
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 ...
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. ...
Doch wenn sie wie geplant ab 2024 gelten, werden einige Unternehmen mit den Härten der GloBE Model Rules eine Begegnung der dritten Art erleben. Dann können einzelne Vermögensübertragungen, die jetzt stattfinden, zu einer Top-up Tax in der Zukunft führen. Grund hierfür ist eine ...
For C-suite leaders, the introduction of Pillar Two global minimum tax rules requires a new approach to data gathering, compliance, and business strategy.
Jersey adopts pillar two legislation The self-governing UK dependency said that over 95% of Jersey companies will be unaffected by pillar two and that Revenue Jersey is ‘well-equipped’ to implement the rules
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....
Pillar IIG20This article addresses the interaction between the Global minimum tax rules (namely, the Income Inclusion and the Undertaxed Payment Rule) with tax treatiesChand, VikramTurina, AlessandroRomanovska, KingaSocial Science Electronic Publishing...
(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’ ...
Interaction of Pillar 2 with the Dutch Corporate Income Tax Act 1969 (CITA) Set to be effective from 1 January 2025, the Proposals furthermore clarify that, for some subject-to-tax rules included in the CITA, Qualifying Pillar 2 Top-up Taxes are recognised as tax on profits. ...