The Transitional CbCR Safe Harbour is included in the OECD Safe Harbour and Penalty Relief Guidance and where it applies it deems the jurisdictional top-up tax to be zero. Read our detailed analysis.

Differences in Accounting Standards have a significant impact on the Pillar Two effective tax rate (ETR) and top-up tax calculation. Read this detailed report.

The Pillar Two rules don’t just apply to companies. They apply to ‘entities’. This means that the Pillar Two GloBE rules can apply to both trusts and foundations.

We have tracked the draft and enacted domestic laws issued to date back to both sets of OECD Administrative Guidance in this matrix for our members. This will be constantly updated as new or amended legislation is issued.

The requirements for a participation exemption under domestic law may not match the exemption requirements in the Pillar Two Rules. Read our analysis.

The QDMTT Safe Harbour excludes the application of the GloBE Rules in other jurisdictions by deeming the Top-up Tax payable under the GloBE Rules to be nil where top-up tax is levied under a QDMTT. In this article, we look at how it applies.

On July 17, 2023, the OECD issued the standardised GloBE Information Return (GIR) that must be submitted by MNE groups within the scope of the GloBE rules.

The Pillar Two rules don’t just apply to companies. They apply to ‘entities’. In this article we look at the application of Pillar Two to trusts and foundations.