Close to 140 countriesagreedto the October 2021 framework, but not to these new model rules. The changes introduce even more uncertainty and complexity to Pillar Two. In addition, the new UTPR may violate many bilateral tax treaties. Pillar Two is starting to look more like a train wreck th...
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 ...
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
We continue to monitor the changes related to the implementation of Pillar 2 rules, and we would be glad to discuss the potential impact of such changes on your business.Download (159 KB) Pillar 2: Release of the Consolidated Commentary to the Global Anti-Base Erosion Model Rules Tax...
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.