It is full steam ahead for implementation of the global minimum tax in the UK and the EU, report Mike Lane and Zoe Andrews (Slaughter and May).
International tax reform: Pillar Two developments
Continuing the trend of piecemeal consultation and guidance sharing as and when ready the OECD published a number of documents at the end of 2022 on the two pillars of international tax reform. Of most interest to financial institutions is the progress of Pillar Two (in particular the global minimum tax or ‘GloBE’ rules).
The GloBE rules provide for a coordinated system of taxation for large multinational enterprises (MNEs) that imposes a top-up tax on profits arising in a jurisdiction whenever the ETR determined on a jurisdictional basis is below the minimum rate of 15%. Quite simple as a concept but incredibly complex when you drill down into the details.
How to achieve tax certainty
It...
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It is full steam ahead for implementation of the global minimum tax in the UK and the EU, report Mike Lane and Zoe Andrews (Slaughter and May).
International tax reform: Pillar Two developments
Continuing the trend of piecemeal consultation and guidance sharing as and when ready the OECD published a number of documents at the end of 2022 on the two pillars of international tax reform. Of most interest to financial institutions is the progress of Pillar Two (in particular the global minimum tax or ‘GloBE’ rules).
The GloBE rules provide for a coordinated system of taxation for large multinational enterprises (MNEs) that imposes a top-up tax on profits arising in a jurisdiction whenever the ETR determined on a jurisdictional basis is below the minimum rate of 15%. Quite simple as a concept but incredibly complex when you drill down into the details.
How to achieve tax certainty
It...
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