The overall design of Pillar 2 consists of two interlocking domestic rules (together the Global anti-Base Erosion Rules (GloBE) Rules): (i) an Income Inclusion Rule (IIR), which imposes top-up tax on a parent entity in respect of the low taxed income of a subsidiary entity; and (ii) ...
The income inclusion rule will apply in some countries, including the UK and the 27 member states of the EU, for years beginning on or after 31 December 2023. Businesses will want to understand the data needed on a real-time basis when the rules take effect in 2024, even though returns ...
As of March 1, 2024, 25 countries (including Japan, South Korea, and the UK) have either introduced draft legislation or adopted final legislation which implement some form of Pillar Two's Model Rules into their national laws. See PwC's Pillar Two Country Tracker for details. Additional ...
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....
The Pillar 2 proposals are more advanced than Pillar 1. Draft legislation was published by the Inclusive Framework in December 2021 and HMRC is currently consulting on how the Pillar 2 rules should be implemented into UK legislation. The regulations focus on a two-step approach for...
The OECD’s business group has criticised pillar two’s model rules for failing to address at least one technical issue. The rules will direct legislation in 137 countries introducing pillar two by 2023.
The GloBE Rules offer jurisdictions a number of legislative options to adopt when implementing a QDMTT. The FSTB and IRD have set out some of their views with regard to these options. However, they have been silent on others. The document seeks feedback on the proposed approaches and inv...
The minimum tax rate decided will have considerable impact on the viability of the Pillar Two proposed rules, particularly if the minimum tax threshold incorporates countries such as Ireland that have low but not nominal tax rates (as is currently in contemplation). Co-existence of GILTI Unlike ...
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