UPE Data Points for the GloBE Information Return

QDMTT Design Features

In this first of a series of articles that will break down all of the data points for the purposes of the Pillar Two GloBE rules (and in particular the expected reporting in the GloBE information return), we look at the UPE data points in the corporate structure.

Japans Pillar 2 Proposals in its 2023 Tax Reform Outline

japan flag

On December 16, 2022, the ruling coalition issued the draft tax reform outline for 2023. This indicates that draft legislation to incorporate an income inclusion rule based on the OECD Model Rules will be put forward in 2023.

U.S Updates its GloBE Impact Document

USA Pillar 2

On December 21, 2022, the Congressional Research Service updated its policy document: The Pillar 2 Global Minimum Tax: Implications for U.S. Tax Policy following the EU adoption of the Global Minimum Tax Directive.