OECD Pillar One Modelling Tool
Our OECD Pillar One Modelling Tool is designed to provide an analysis of the high-level impact of Amount A of Pillar One.
Pillar Two: Investment Companies Top-Up Tax Calculator
Our Investment Companies Top-Up Tax Calculator models the impact of Pillar Two in a jurisdiction where there are a mix of investment and non-investment companies.
A Review of the Amount A Double Tax Relief Rules
The Amount A elimination of double taxation provisions in Title 5 of the Progress Report on Amount A of Pillar One apply to prevent a multinational group being taxed twice on profits allocated to a market jurisdiction where there is already some form or physical establishment that is subject to tax.
Analysis of South Korea’s Draft Pillar Two Law
On July 22, 2022, South Korea released a draft law to implement the OECD’s Pillar Two GloBE Rules (the ‘draft law’) in legislative notice 2022-128. Read our analysis.
Analysis of Switzerlands Draft Pillar Two Decree
On August 17, 2022, the Swiss Federal Council issued a draft decree for the implementation of Pillar Two of the OECDs Two Pillar Solution from January 1, 2024. Read our detailed analysis.
Pillar One: Amount A Revenue Sourcing Rules Interactive Tool
The Revenue Sourcing Rules for Amount A are used to determine where an in-scope multinational group derives its revenues. This is then used in the profit reallocation calculation.
Use our interactive tool to quickly determine the relevant sourcing rule for each revenue type.
Pillar One Reliable Indicators – An Analysis
The Amount A reliable indicators are the practical methods of allocating revenue to jurisdictions for the purposes of the Pillar One, Amount A revenue sourcing rules.
Allocation Keys for Sourcing Revenue under Amount A
Allocation Keys are a key aspect of the Amount A Revenue Sourcing Rules, which attribute revenue to the jurisdictions an MNE group operates in. This is then used when determining how much profit is reallocated to a jurisdiction.
Marketing and Distribution Profits Safe Harbour: An Example
The marketing and distribution profits safe harbour is included in Articles 6(3)-(6) of the Progress Report on Amount A of Pillar One. It is deducted from the initial amount of profits reallocated to a jurisdiction (but cannot reduce profits below zero). One of the purposes of the safe harbour is to prevent double taxation, where […]
GloBE Loss Election – Interactive Tool
Our GloBE Loss Election interactive tool allows you simulate the impact on your top-up tax liability depending on whether a GloBE Loss Election is made or not.
