OECD Consultation on Tax Certainty for the GloBE Rules
On December 20, 2022, the OECD published a consultation document on Tax Certainty for the GloBE Rules. We look at the key highlights.
On December 20, 2022, the OECD published a consultation document on Tax Certainty for the GloBE Rules. We look at the key highlights.
Today the OECD announced details of two safe harbours and a penalty relief provision for the Pillar Two GloBE rules.
Pension funds are subject to a number of specific provisions under the Pillar Two rules. In this article we look at some of the key aspects of Pillar Two that impact on Pension Funds.
Whilst a number of the measures follow the proposals in the November Staff Paper, the prospect of certain other additional disclosures not previously suggested, has been put forward. In this article we review the IASB’s announcement and proposed changes.
Insurance Investment Entities are subject to special treatment under the Pillar Two GloBE Rules. Read our analysis of the key provisions.
The Pillar Two Rules include specific provisions for tax transparent entities to avoid artificially low effective tax rates and significant top-up tax, particularly for tax transparent UPEs.
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.
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.
The OECD issued a report yesterday on tax incentives after Pillar 2. We look at the key takeaways including which tax incentives have the largest impact.
The Subject-to-Tax Rule is a key component of Pillar Two, and unlike the GloBE Rules focuses on source jurisdictions. Our members-only global map highlights domestic withholding taxes at less than the 9% rate under the Subject-to-Tax Rule.
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