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Pillar Two Report: MNE Systems Planning

Pillar Two Report: MNE Systems Planning
The Pillar Two GloBE Rules will have a significant impact on MNEs.
 
They will need to calculate jurisdictional effective tax rates using the GloBE rules (as implemented domestically) and account for any top-up tax using the income inclusion rule or the under-taxed payments rule.
 
However, the first step is to ensure that (a) the systems are in place to allow the various calculations to be undertaken, and (b) the group structure should be reviewed to identify areas which are inefficient from a GloBE perspective.
 
In this 35 page report we take a systems-based approach to the GloBE rules and look at both of these aspects.
 
Contents
 
  1. Centralized Vs Decentralized Data Management
  2. Tax Data Mapping
  3. Profit Extraction after Pillar Two
  4. Use of SPVs after Pillar Two
  5. The Impact of Pillar Two on Group Payroll Companies
  6. The Impact of Pillar Two on Group Financing Companies
  7. Pillar Two Accounting Disclosures
  8. Tracking Deferred Tax Adjustments
  9. Pillar Two Restructuring for MNEs
 
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Picture of Lee Hadnum

Lee Hadnum

Lee is a qualified Chartered Accountant and Chartered Tax Adviser. A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

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