Tim Sarson (KPMG) reports on a flurry of activity across the international
tax world and looks ahead at what to expect in 2024.
OECD
Administrative Guidance for Pillar Two and update on Pillar One timeline
On 18 December 2023 the Inclusive Framework (IF) released its third tranche of Administrative Guidance on the Global Anti-Base Erosion (GloBE) Model Rules. The guidance principally covers the application of the Transitional Country by Country Reporting (CbCR) Safe Harbour (TCSH) in particular when purchase pricing accounting adjustments do and do not need to be excluded from a MNE’s group’s qualified CbCR. It also addresses issues such as the allocation of blended CFC taxes (notably US GILTI) and filing deadlines for groups with short reporting periods.
On the same day the OECD released a statement on the timeline for the multilateral convention (MLC) under Amount A of Pillar One. Recognising that...
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Tim Sarson (KPMG) reports on a flurry of activity across the international
tax world and looks ahead at what to expect in 2024.
OECD
Administrative Guidance for Pillar Two and update on Pillar One timeline
On 18 December 2023 the Inclusive Framework (IF) released its third tranche of Administrative Guidance on the Global Anti-Base Erosion (GloBE) Model Rules. The guidance principally covers the application of the Transitional Country by Country Reporting (CbCR) Safe Harbour (TCSH) in particular when purchase pricing accounting adjustments do and do not need to be excluded from a MNE’s group’s qualified CbCR. It also addresses issues such as the allocation of blended CFC taxes (notably US GILTI) and filing deadlines for groups with short reporting periods.
On the same day the OECD released a statement on the timeline for the multilateral convention (MLC) under Amount A of Pillar One. Recognising that...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
