The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
New taxing right: regulated financial services exclusion
Although concerns remain about how and when ‘Amount A’ of pillar one of international tax reform might be implemented in particular by the US the OECD continues to consult on the individual building blocks of the new rules. The consultation on the proposed regulated financial services (RFS) exclusion which closed on 20 May gives an insight into how the exclusion will apply. Amount A introduces a new taxing right for market jurisdictions over the residual profits of the largest and most profitable enterprises.
The starting point is that the revenues and profits of regulated financial institutions (RFIs) will be excluded from Amount A although it has not yet been agreed if this exclusion should cover reinsurance and asset management. The effect...
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The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
New taxing right: regulated financial services exclusion
Although concerns remain about how and when ‘Amount A’ of pillar one of international tax reform might be implemented in particular by the US the OECD continues to consult on the individual building blocks of the new rules. The consultation on the proposed regulated financial services (RFS) exclusion which closed on 20 May gives an insight into how the exclusion will apply. Amount A introduces a new taxing right for market jurisdictions over the residual profits of the largest and most profitable enterprises.
The starting point is that the revenues and profits of regulated financial institutions (RFIs) will be excluded from Amount A although it has not yet been agreed if this exclusion should cover reinsurance and asset management. The effect...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
