The OECD has released further technical guidance on implementation of the global minimum tax under Pillar Two and a statement updating the timeframe for the Multilateral Convention to implement Amount A of Pillar One.
The Inclusive Framework’s further guidelines are designed to help governments implement the Pillar Two global minimum tax rate. The guidance covers the transitional country-by-country reporting safe harbour (section 2) and allocation of taxes arising in a blended controlled foreign company (CFC) tax regime when a multinational enterprise (MNE) operates in jurisdictions eligible for the safe harbour (section 4).
Further administrative guidance can be expected as the need arises, according to the OECD, including ‘to address aggressive tax planning that may undermine the integrity of the rules or their application to certain MNE Groups’.
In the first half of 2024, the Inclusive Framework intends to publish guidance on the application of deferred tax liability recapture rules and the allocation of deferred taxes relating to cross-border taxes such as CFC tax regimes.
In a separate, short statement on progress towards a Multilateral Convention to implement Amount A of Pillar One (the text for which was published in October 2023), the Inclusive Framework acknowledges ongoing work to ‘resolve the remaining differences’ and commits to achieving a consensus-based solution, finalising the text for the convention by the end of March 2024.
The OECD has released further technical guidance on implementation of the global minimum tax under Pillar Two and a statement updating the timeframe for the Multilateral Convention to implement Amount A of Pillar One.
The Inclusive Framework’s further guidelines are designed to help governments implement the Pillar Two global minimum tax rate. The guidance covers the transitional country-by-country reporting safe harbour (section 2) and allocation of taxes arising in a blended controlled foreign company (CFC) tax regime when a multinational enterprise (MNE) operates in jurisdictions eligible for the safe harbour (section 4).
Further administrative guidance can be expected as the need arises, according to the OECD, including ‘to address aggressive tax planning that may undermine the integrity of the rules or their application to certain MNE Groups’.
In the first half of 2024, the Inclusive Framework intends to publish guidance on the application of deferred tax liability recapture rules and the allocation of deferred taxes relating to cross-border taxes such as CFC tax regimes.
In a separate, short statement on progress towards a Multilateral Convention to implement Amount A of Pillar One (the text for which was published in October 2023), the Inclusive Framework acknowledges ongoing work to ‘resolve the remaining differences’ and commits to achieving a consensus-based solution, finalising the text for the convention by the end of March 2024.
