Profit Shifting to CFCs to Reduce Pillar 2 Top-Up Tax
December 2, 2022
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Article 4.3.2(c) of the OECD Model Rules allocates tax paid on CFC income to the CFC entity (subject to a pushdown limitation). However, this
Pension funds are subject to a number of specific provisions under the Pillar Two rules. In this article we look at some of the key
Our Global VAT on Digital Services Tracker has been updated and now covers over 80 jurisdictions.
Whilst a number of the measures follow the proposals in the November Staff Paper, the prospect of certain other additional disclosures not previously suggested, has
Our Modelling Tool takes the underlying source data from the OECD aggregated CbC source data and subjects it to a data manipulation process to provide
Insurance Investment Entities are subject to special treatment under the Pillar Two GloBE Rules. Read our analysis of the key provisions.
Luxembourg is home to the second largest funds industry in the world and the largest in Europe. In this article we look at the Pillar
Use our Global map to determine the effective tax rate for R&D expenditure globally. Including the average R&D ETR per jurisdiction and the impact of
Following draft legislation issued in July 2022, the UK government confirmed in this week’s Autumn Statement that they will legislate to implement Pillar Two from
The OECD issued the Fourth Edition of its Corporate Tax Statistics report yesterday. The Press Release that accompanied the report stated that the report supported the need
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