Oecd G20 Base Erosion And Profit Shifting Project Tax Challenges Arising From The Digitalisation Of The Economy Commentary To The Global Anti Base Erosion Model Rules Pillar Two First Edition Inclusive Framework On Beps
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OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from the Digitalisation of the Economy – Commentary to the Global Anti-Base Erosion Model Rules (Pillar Two), First Edition Inclusive Framework on BEPS
A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation of the economy. In October 2021, over 135 jurisdictions joined a ground-breaking plan to update key elements of the international tax system which is no longer fit for purpose in a globalised and digitalised economy.
Annotations on the OECD Global Anti-Base Erosion Model Rules (Pillar 2)
Author: Dennis Weber
language: en
Publisher: Kluwer Law International B.V.
Release Date: 2024-09-16
Although still under development, Pillar 2 of the OECD Global Anti-Base Erosion Model Rules is already posing significant challenges for taxation authorities worldwide. Intended to establish a floor in the possibilities for countries to compete for corporate investment with each other in the field of corporate income taxation, the Pillar 2 Rules arising from the OECD/G20 Inclusive Framework have been agreed on by 140 countries. This book provides the first in-depth survey of the implications of the Rules for all stakeholders, with detailed annotations by nineteen renowned experts in the field of multinational corporate taxation who describe the relevant provisions with examples and considerations addressing their scope, functioning, and interaction. Undergirded by a comprehensive discussion of the Rules, their technical operation, and the administrative guidance provided by OECD, topics covered include the following: definitions of tax terms for Pillar 2 purposes; computation of income or loss, adjusted covered taxes, effective tax rate, and top-up tax; jurisdictional blending and loss offsets; effect of corporate restructurings and holding structures; excluded categories of income; carve-out opportunities under the Substance-Based Income Exclusion (SBIE); transitional country-by-country and time-limited safe harbours; and differences and interactions between the OECD Global Anti-Base Erosion (GloBE) and both the EU Pillar 2 Directive and the US Global Intangible Low-Taxed Income (GILTI) regimes. It has been estimated that the GloBE reform would produce a worldwide additional tax revenue of USD 200 billion annually. It has thus become imperative for taxation authorities, tax practitioners, and multinational corporate counsel to become as aware as possible of the intricacies of the Pillar 2 Rules, and for this reason, this detailed discussion and analysis will be greatly appreciated by taxation professionals worldwide.
Pillar Two of the Inclusive Framework on BEPS
Author: Carlo Garbarino
language: en
Publisher: Edward Elgar Publishing
Release Date: 2024-09-06
Adopting a practical problem-solving approach, this book critically analyses the recent OECD Global Anti-Base Erosion Model Rules that have been adopted to address the tax challenges arising from the digitalisation of the economy. It provides a clear and systematic explanation of Pillar Two and the OECD policies, which are now being implemented in a variety of national tax systems.