Transitional Penalty Relief Regime

This is another temporary provision to relax penalties for MNEs in the initial years of the application of the GloBE Rules.
 
It applies for fiscal years beginning on or before December 31, 2026 but not after June 30, 2028, and provides that during this period, no penalties should apply relating to the filing of a GloBE Information Return where an MNE has taken “reasonable measures” to ensure the correct application of the GloBE Rules.
 
This will be at the discretion of tax authorities but the OECD notes that an MNE that can demonstrate that it has acted in good faith to understand and comply with the domestic application of the GloBE Rules and any QDMTT, this is likely to be viewed as taking reasonable measures.

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The Impact of the Different ETR Calculation for Investment Funds

The Pillar Two effective tax rate (ETR) calculation for investment entities is similar to the standard ETR calculation, however, there is an important twist in that the top-up tax is adjusted for minority interests. There is no adjustment for minority interests under the standard ETR calculation. In this article we look at the impact of this.

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