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.
Centralized Vs Decentralized Data Management
Tax Data Mapping
Profit Extraction after Pillar Two
Use of SPVs after Pillar Two
The Impact of Pillar Two on Group Payroll Companies
The Impact of Pillar Two on Group Financing Companies
Pillar Two Accounting Disclosures
Tracking Deferred Tax Adjustments
Pillar Two Restructuring for MNEs
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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.
This website is not affiliated with or related to the OECD. We provide independent insights and analysis on the OECD Two-Pillar Solution