Cloud-based software for advanced Pillar Two analytics and insights.
Our Pillar Two Tax Engine allows you to model the impact of the Pillar Two GloBE Rules and any top-up tax liability, determine best and worst-case scenarios and simulate the impact of making various GloBE elections.
Our Pillar One Modelling Tool provides a calculation of the estimated profits reallocated to jurisdictions under Amount A of Pillar One and the estimated corporate income tax on those reallocated profits.
Given Pillar One feeds directly into Pillar Two, it also estimates the Pillar Two top-up tax liability after the application of Pillar One.
Free access for site members.
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.
Yesterday the Financial Accounting Standards Board (FASB) issued a Tentative Decision on the treatment under US GAAP of deferred taxes for the GloBE minimum tax.
See our infographic for the impact of the proposed IASB Pillar 2 amendments to IAS 12 for MNEs with a December 31 year end.
Calculate estimated GloBE top-up tax. Add unlimited companies and jurisdictions via an easy to use control panel to view potential jurisdictional liabilities.
Foreign tax credits interact with the Pillar Two GloBE Rules in a number of ways. In this article we assess the key impact.
Our Modelling Tool takes the underlying source data from the OECD aggregated CbC source data and subjects it to a data manipulation process to provide a drill down into some of the key metrics and data sources that are relevant for Pillar Two on a jurisdictional basis.
Use our members Income Inclusion Rule Calculator to see how the IIR applies. Enter details of the low-taxed entity including jurisdictional GloBE income and other relevant information to determine top-up tax payable by the parent company.
Following the approval of the EU Global Minimum Tax Directive, Taiwan’s Ministry of Finance has stated it will prepare draft legislation for the government to increase Taiwan’s domestic minimum tax rate from 12% to 15%.
However, this creates a number of issues in terms of its interaction with the Pillar Two global minimum tax.
Liechtenstein has announced it is to issue a consultation on a Pillar Two Global Minimum Tax in March 2023.
The GloBE rules include a number of insurance specific adjustments. In this article we look at the nature of these provisions as well as the impact of the GloBE rules on insurance companies generally.
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.
Our Global Digital Services Tax Tracker has been updated to January 23, 2023.
In this article, we look at the potential impact of the Pillar Two GloBE Rules for MNEs operating in the Philippines.
On December 20, 2022, Indonesia issued Government Regulation No. 55/2022 on the Adjustment of Regulations in the Field of Income Tax. This included reference to the implementation of a global minimum tax in Indonesia as well a a desire to implement Pillar One.
Today’s OECD webinar on Tax challenges of digitalisation: Economic impact assessment of the Two-Pillar Solution reported that revenue gains from both Pillar One and Pillar Two is expected to increase from the previous economic impact assessment.
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.
With the enactment of the Pillar Two GloBE Rules in South Korea from January 1, 2024, the costs of an unintentional permanent establishment (PE) in South Korea may be significantly greater.
Our members-only modelling tool carries out the calculations based on the required inputted information to determine whether the Transitional CbCR Safe Harbour applies.
The GloBE Information Return will require information on an MNEs corporate structure in so far as it impacts the application of the Pillar Two GloBE rules. In this article we look at the data points that are required to comply with this.
As a members only resource, we include an unofficial English translation of the South Korean Global Minimum Tax Law (Law 19191 of December 31, 2022).
Today, the International Accounting Standards Board (IASB) issued an Exposure Draft for proposed amendments to IAS 12 to take account of the Pillar Two Model Rules.
On December 31, 2022 the first domestic law was enacted to give effect to the Pillar Two GloBE rules from January 1, 2024. Read more.
In this first of a series of articles that will break down all of the data points for the purposes of the Pillar Two GloBE rules (and in particular the expected reporting in the GloBE information return), we look at the UPE data points in the corporate structure.
The International Accounting Standards Board (IASB) has stated it expects to publish its Exposure Draft on the Pillar Two Model Rules on January 9, 2023. Read more.
The African Tax Administration Forum (ATAF) has released a Suggested Approach to Drafting Domestic Minimum Top-Up Tax Legislation under the Pillar Two GloBE Rules.
We can expect to see a substantial number of countries releasing and enacting legislation to implement Pillar Two in 2023.
On December 16, 2022, the ruling coalition issued the draft tax reform outline for 2023. This indicates that draft legislation to incorporate an income inclusion rule based on the OECD Model Rules will be put forward in 2023.
On December 21, 2022, the Congressional Research Service updated its policy document: The Pillar 2 Global Minimum Tax: Implications for U.S. Tax Policy following the EU adoption of the Global Minimum Tax Directive.
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.
Calculate estimated GloBE top-up tax. Add unlimited companies and jurisdictions via an easy to use control panel to view potential jurisdictional liabilities.
Our Modelling Tool takes the underlying source data from the OECD aggregated CbC source data and subjects it to a data manipulation process to provide a drill down into some of the key metrics and data sources that are relevant for Pillar Two on a jurisdictional basis.
Use our members Income Inclusion Rule Calculator to see how the IIR applies. Enter details of the low-taxed entity including jurisdictional GloBE income and other relevant information to determine top-up tax payable by the parent company.
Our Global Digital Services Tax Tracker has been updated to January 23, 2023.
Our members-only modelling tool carries out the calculations based on the required inputted information to determine whether the Transitional CbCR Safe Harbour applies.
Our Global VAT on Digital Services Tracker has been updated and now covers over 80 jurisdictions.
Use our global assessment tool to determine the VAT position on the provision of international digital services. The tool is fully cited to the relevant domestic law.
Use our Global map to determine the effective tax rate for R&D expenditure globally. Including the average R&D ETR per jurisdiction and the impact of incentives.
Global intellectual property (IP) incentives have grown in recent years. Use our tool to compare different regimes.
This Modelling Tool accompanies our analysis Modelling the Impact of Payroll Tax Incentives Post Pillar 2. Members use this tool to adjust key variables.
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.
For Pillar Two purposes, investments in fixed assets can involve an interaction between deferred tax impacts and the the substance-based income exclusion.
Our interactive map covers the current global treatment of VAT on digital services. Fully cited with links to relevant laws.
Our interactive map breaks down worldwide corporate income tax rates to identify jurisdictions with a headline CIT rate below the Pillar Two 15% rate.
Our Global Digital Services Tax Tracker allows you to stay up to date with international digital service taxes. Cited and with links to domestic legislation.
Our OECD Pillar One Modelling Tool is designed to provide an analysis of the high-level impact of Amount A of Pillar One.
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.
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.
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.
Our Qualified Domestic Minimum Top-Up Tax (QDMTT) interactive tool allows you simulate the impact on your top-up tax liability depending on whether the domestic top-up tax is a QDMTT or is non-qualifying.
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