The OECD is seeking comments on compliance and coordination aspects of the Pillar Two global minimum tax. Two documents have been published for consultation:
GloBE information return: seeking input on the amount and type of information that MNE groups should be expected to collect, retain and/or report for the application of the GloBE rules, and possible simplifications that could be incorporated in the GloBE information return as well as the ability of the MNE group to provide alternative data points.
Tax certainty for the GloBE rules: seeking views on potential next steps in connection with the development of various mechanisms, including dispute prevention and resolution, for achieving tax certainty under the Globe rules.
Comments are invited by 3 February 2023. The OECD has also published a ‘further progress’ update page on Pillars One and Two.
Guidance has been issued on Pillar Two safe harbours and penalty relief. This includes the agreed terms of a transitional country by country reporting safe harbour that effectively removes the obligation of calculating the GloBE effective tax rate for an MNE’s operations in lower-risk jurisdictions in the initial years. There is a framework for the development of permanent safe harbours as simplified income and tax calculations, as well as a common understanding as to a transitional penalty relief regime for applying penalties or sanctions where an MNE has taken reasonable measures to ensure the correct application of the GloBE rules.
Going forward, the Inclusive Framework expects to release administrative guidance on the interpretation or administration of the global minimum tax on a rolling basis, with the first package of administrative guidance to be released in early 2023. Work is also proceeding on the finalisation of the subject to tax rule and the related multilateral instrument to assist in its implementation.
Further information on the two-pillar solution for addressing the tax challenges arising from digitalisation and globalisation of the economy is available at https://oe.cd/bepsaction1.
The OECD is seeking comments on compliance and coordination aspects of the Pillar Two global minimum tax. Two documents have been published for consultation:
GloBE information return: seeking input on the amount and type of information that MNE groups should be expected to collect, retain and/or report for the application of the GloBE rules, and possible simplifications that could be incorporated in the GloBE information return as well as the ability of the MNE group to provide alternative data points.
Tax certainty for the GloBE rules: seeking views on potential next steps in connection with the development of various mechanisms, including dispute prevention and resolution, for achieving tax certainty under the Globe rules.
Comments are invited by 3 February 2023. The OECD has also published a ‘further progress’ update page on Pillars One and Two.
Guidance has been issued on Pillar Two safe harbours and penalty relief. This includes the agreed terms of a transitional country by country reporting safe harbour that effectively removes the obligation of calculating the GloBE effective tax rate for an MNE’s operations in lower-risk jurisdictions in the initial years. There is a framework for the development of permanent safe harbours as simplified income and tax calculations, as well as a common understanding as to a transitional penalty relief regime for applying penalties or sanctions where an MNE has taken reasonable measures to ensure the correct application of the GloBE rules.
Going forward, the Inclusive Framework expects to release administrative guidance on the interpretation or administration of the global minimum tax on a rolling basis, with the first package of administrative guidance to be released in early 2023. Work is also proceeding on the finalisation of the subject to tax rule and the related multilateral instrument to assist in its implementation.
Further information on the two-pillar solution for addressing the tax challenges arising from digitalisation and globalisation of the economy is available at https://oe.cd/bepsaction1.
