While a coordinated roll-out of rules was once an aspiration, the reality is anything but, explain Ashley Greenbank and Rhiannon Kinghall Were (Macfarlanes).
As domestic legislation is laid out to implement the OECD Pillar Two project a complex picture is beginning to emerge. Groups that have a presence in delayed or even non-implementing jurisdiction in combination with early adopting jurisdictions will need to understand the interaction between the different layers of the rules and the various timelines for implementation. While a coordinated roll-out of rules was once an aspiration the reality is anything but.
Interlinking rules
By way of recap the main components of Pillar Two are the GloBE rules which include the income inclusion rule (IIR) and the undertaxed profit rule (UTPR). They aim to ensure that large multinational groups pay a minimum effective tax rate (ETR) of at least 15% on profits in every jurisdiction...
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While a coordinated roll-out of rules was once an aspiration, the reality is anything but, explain Ashley Greenbank and Rhiannon Kinghall Were (Macfarlanes).
As domestic legislation is laid out to implement the OECD Pillar Two project a complex picture is beginning to emerge. Groups that have a presence in delayed or even non-implementing jurisdiction in combination with early adopting jurisdictions will need to understand the interaction between the different layers of the rules and the various timelines for implementation. While a coordinated roll-out of rules was once an aspiration the reality is anything but.
Interlinking rules
By way of recap the main components of Pillar Two are the GloBE rules which include the income inclusion rule (IIR) and the undertaxed profit rule (UTPR). They aim to ensure that large multinational groups pay a minimum effective tax rate (ETR) of at least 15% on profits in every jurisdiction...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
