Distribution Tax Regime Election

Distribution Tax Regime Election Contents What is a Distribution Tax Regime? Article 7.3.1 of the OECD Model Rules permits a constituent entity to to make

Deemed Disposal of Assets Election

Deemed Disposal of Assets In some jurisdictions there can be a deemed disposal of assets. This occurs in the UK for instance where a company

Excluded Entity Election

Excluded Entity Election Excluded entities are not taken into account for the purposes of calculating the jurisdictional effective tax rate, any top-up tax payment and

Taxable Distribution Method Election

Taxable Distribution Method Election Contents Taxable Distribution Method Election, Generally The taxable distribution method election is an election available for investment entities and is an

Tax Transparency Election

Tax Transparency Election An entity can make a tax transparency election in respect of its ownership interest in an investment entity. This then changes the

GloBE Loss Election

GloBE Loss Election Contents GloBE Loss Election GloBE Loss Election, Generally GloBE Loss Election – Example 1, No Corporate Income Tax GloBE Loss Election –

Consolidation Election

Consolidation Election Whilst consolidated financial accounts are used for determining whether MNE groups are in scope (see our Scope analysis), Pillar Two GloBE income is

Capital Gains Election

Election to Spread Capital Gains A capital gains election allows an MNE group to spread gains and losses on sales of local immovable tangible assets

Stock-Based Compensation Election

Stock Based Compensation Election Overview Article 3.2.2 of the OECD Model Rules include an election (the ‘stock-based compensation election’) to replace the deductible amount of