As an alternative to incurring additional top-up tax when a domestic tax loss exceeds the GloBE loss, Article 2.7 of the OECD Administrative Guidance provides that an MNE can elect for the Excess Negative Tax Expense administrative procedure.
Article 2.8 of the OECD Administrative Guidance provides for the inclusion of deferred tax in the GloBE deferred tax adjustment amount for ‘Substitute Loss Carry Forwards’.
The OECD Administrative Guidance provides details on which aspects of the GloBE Rules need to be reflected in the QDMTT regime and which aspects don’t.
Article 2.10 of the Administrative Guidance provides more information on the treatment of the US Global Intangible Low-Taxed Income (GILTI) regime.
Today the OECD has issued the Agreed Administrative Guidance for the Pillar Two GloBE Rules. This is the final part of the implementation framework for the GloBE Rules.
See our infographic for the impact of the proposed IASB Pillar 2 amendments to IAS 12 for MNEs with a December 31 year end.
In this article we take a comprehensive look at how the substance-based income exclusion applies including the various adjustments for permanent establishments and flow-through entities and the data points required.
Just because the statutory rate of corporate income tax is significantly below 15% does not necessarily mean that top-up tax would apply under the Pillar Two global minimum tax rules. We look at why in this article.
On December 20, 2022, the OECD published a consultation document on the Pillar Two GloBE Information Return which includes 268 data points for MNEs to collect.
On December 20, 2022, the OECD published a consultation document on Tax Certainty for the GloBE Rules. We look at the key highlights.
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