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New: Pillar Two Workflow - generate GIR/GloBE, safe harbour and evidence workflows in one workspace. Open Workflow Beta

Author: Lee Hadnum

Lee is a qualified Chartered Accountant and a former Senior Tax Analyst at Bloomberg Tax. Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.

The Use of Corporate Income Tax Incentives to Attract FDI After Pillar Two

image showing tax and the data points that flow into it

In this analysis we look at the key corporate tax incentives and assess their potential FDI impact taking into account the Pillar Two GloBE Rules. 

The Use of Corporate Income Tax Incentives to Attract FDI After Pillar Two

image showing tax and the data points that flow into it

In this analysis we look at the key corporate tax incentives and assess their potential FDI impact taking into account the Pillar Two GloBE Rules. 

Why MNEs Should Reassess SPVs in Light of Pillar Two

Group Structure - SPVs

The nature of the Pillar Two GloBE Rules means that in some cases, SPVs can lead to top-up tax that would not occur if a subsidiary was directly held.

A Review of China’s Tax Law From a Pillar Two Perspective

china's flag

In this analysis we look at the key features of China’s tax law that would need to be taken into account by MNEs with Chinese subsidiaries for Pillar 2 purposes.

Payroll Tax Incentives – Pillar Two Modelling Tool

Image showing payroll tax incentives modelling tool

This Modelling Tool accompanies our analysis Modelling the Impact of Payroll Tax Incentives Post Pillar 2. Members use this tool to adjust key variables.

Modelling the Impact of Payroll Tax Incentives Post Pillar 2

image showing payroll

In a post Pillar Two environment, the nature of tax incentives needs to be carefully considered to ensure that both MNEs and tax authorities derive benefits. In this analysis we model the impact of payroll tax incentives.

India’s Tax Regime after Pillar Two: Key Risks and Opportunities

Indias Flag

In this article we look at India’s corporate income tax regime and assess the impact of the Pillar Two GloBE Rules on MNE’s with operations in India.

The Thorny Issue of Pillar Two in Vietnam

vietnam flag

Vietnam’s broad income-based tax incentives could impact on investment into Vietnam in a post Pillar Two environment. We look at the issues and policy options.

Highlights of the OECD Progress Report on the Administration of Amount A

OECD Report

On October 6, 2022, the OECD issued the Progress Report on the Administration and Tax Certainty Aspects of Amount A of Pillar One (the ‘Progress Report’), which includes draft Model Rules on the administration of Amount A.

Global Developments with Pillars 1 & 2 Last Week

data points for the substance-based income exclusion

In this members article we look at key developments last week, including Ireland, Vietnam, Belgium and the OECD.

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