The intention of Pillar Two is to ensure that the income of enterprises arising in the countries in which they operate is taxed at an effective rate of at least 15 % through the levying of a "top-up tax". Not all details of the Pillar Two rules have been fully clarified. Nevertheless...
The OECD inclusive framework’s Pillar Two model rules, applicable to large multinational groups with annual consolidated group revenue of at least EUR 750 million, will result in “top-up” tax amounts to bring the overall tax on profits in each jurisdiction where a group operates up to a m...
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 ...
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
Public consultation document: Pillar One—Amount A: Draft model rules for tax base determinations. https://www.oecd.org/tax/beps/public-consultationdocument-pillar-one-amount-a- tax-base-determinations.pdf. OECD. (...
Pillar Two Subject to Tax Rule (STTR); Pillar Two GloBE information return; and The second set of Pillar Two administrative guidance. 17 July 2023 136 jurisdictions agree on a new international corporate tax framework under BEPS 2.0 Mainland China and Hong Kong SAR are amongst the 136 jurisdicti...
The first set of mechanisms should apply at an early stage in advance of any taxation action being taken,ie,in the compliance or assessment process. Relying on these mechanisms should prevent inconsistent outcomes when applying the Model Rules given possible ...
As the effective date for BEPS Pillar Two approaches, it is crucial for MNEs to accelerate their preparation efforts. While significant challenges remain, proactive planning, strategic investments in technology, and enhanced global collaboration will be key to achieving compliance. The insights from this...
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. ...
Guernsey has approved legislation to implement the OECD’s Pillar Two rules, which is effective from 1 January 2025.