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International review for January 2022

Tim Sarson (KPMG) reports on a busy start to what promises to be an eventful year for the international tax world.

Pillar two model rules

Work by the OECD to implement a minimum global corporate tax rate has continued in earnest. Following the release of the October 2020 blueprint for global anti-base erosion (GloBE) rules under pillar two of the BEPS 2.0 project on 20 December 2021 the OECD/G20 Inclusive Framework (IF) involving 137 countries released more detailed model rules.

The rules provide a template to help countries introduce domestic legislation to ensure multinational enterprises (MNEs) with a turnover of more than €750m pay a minimum level of 15% tax on income arising in each of the jurisdictions in which they operate. Where the effective tax rate (ETR) in a jurisdiction falls below 15% the rules determine an amount of top-up tax for each constituent...

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