Tim Sarson (KPMG) provides a recap of recent Pillar One and Two developments, and looks ahead to what’s in store throughout 2023.
Pillar Two implementation package published
On 20 December 2022 the OECD/G20 Inclusive Framework (IF) on BEPS released its much-anticipated Pillar Two implementation package. The package includes three documents:
1. Guidance on safe harbours and penalty relief: this is designed to minimise the compliance burden associated with undertaking full GloBE effective tax rate calculations in respect of ‘lower risk jurisdictions’. The guidance includes a transitional country-by-country reporting (CbCR) safe harbor that has already been agreed by the IF and a framework for the development of a potential permanent safe harbour. There are also proposals for a transitional penalty relief regime when an MNE has taken ‘reasonable measures’ to correctly apply the GloBE rules. It is noteworthy that one of the most requested safe harbours during the April public...
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Tim Sarson (KPMG) provides a recap of recent Pillar One and Two developments, and looks ahead to what’s in store throughout 2023.
Pillar Two implementation package published
On 20 December 2022 the OECD/G20 Inclusive Framework (IF) on BEPS released its much-anticipated Pillar Two implementation package. The package includes three documents:
1. Guidance on safe harbours and penalty relief: this is designed to minimise the compliance burden associated with undertaking full GloBE effective tax rate calculations in respect of ‘lower risk jurisdictions’. The guidance includes a transitional country-by-country reporting (CbCR) safe harbor that has already been agreed by the IF and a framework for the development of a potential permanent safe harbour. There are also proposals for a transitional penalty relief regime when an MNE has taken ‘reasonable measures’ to correctly apply the GloBE rules. It is noteworthy that one of the most requested safe harbours during the April public...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
