Your monthly review of latest developments, by Tim Sarson (KPMG).
OECD: release of fourth tranche of Administrative Guidance on GloBE Model Rules
On 17 June 2024 the OECD/G20 Inclusive Framework (IF) released its fourth tranche of Administrative Guidance on the Global Anti-Base Erosion (GloBE) model rules (‘June 24 AG’). At 140 pages a detailed analysis of the June 24 AG is outside the scope of this article. I have summarised below some key points of interest but note this is not exhaustive.
Detailed recapture rules for Deferred Tax Liabilities (DTLs)
The GloBE rules stipulate that the accrual of a DTL that does not reverse within five years will be subject to recapture with a MNE group required to re-compute its GloBE effective tax rate (ETR) excluding such DTLs and pay any additional top-up tax due.
MNE groups had raised concerns with the IF...
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Your monthly review of latest developments, by Tim Sarson (KPMG).
OECD: release of fourth tranche of Administrative Guidance on GloBE Model Rules
On 17 June 2024 the OECD/G20 Inclusive Framework (IF) released its fourth tranche of Administrative Guidance on the Global Anti-Base Erosion (GloBE) model rules (‘June 24 AG’). At 140 pages a detailed analysis of the June 24 AG is outside the scope of this article. I have summarised below some key points of interest but note this is not exhaustive.
Detailed recapture rules for Deferred Tax Liabilities (DTLs)
The GloBE rules stipulate that the accrual of a DTL that does not reverse within five years will be subject to recapture with a MNE group required to re-compute its GloBE effective tax rate (ETR) excluding such DTLs and pay any additional top-up tax due.
MNE groups had raised concerns with the IF...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
