Pillar Two Of The Inclusive Framework On Beps
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Tax Challenges Arising from Digitalisation - Report on Pillar Two Blueprint
The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project aims to create a single set of consensus-based international tax rules to address BEPS, and hence to protect tax bases while offering increased certainty and predictability to taxpayers. Addressing the tax challenges raised by digitalisation has been a top priority of the OECD/G20 Inclusive Framework in BEPS since 2015 with the release of the BEPS Action 1 Report. At the request of the G20, the Inclusive Framework has continued to work on the issue, delivering an interim report in March 2018. In 2019, members of the Inclusive Framework agreed to examine proposals in two pillars which could form the basis for a consensus solution to the tax challenges arising from digitalisation. That same year, a programme of work to be conducted on Pillar One and Pillar Two was adopted and later endorsed by the G20. This report explores options and issues in connection with the design of a global minimum tax that would address remaining BEPS issues.
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.
The Global Minimum Tax | Selected Issues on Pillar Two
Author: Valentin Bendlinger
language: en
Publisher: Linde Verlag GmbH
Release Date: 2024-10-18
Global Minimum Tax at a glance The OECD ́s Global Minimum Tax is amongst the most discussed topics in the recent international tax law debate. The book provides for more than 25 individual but co-ordinated essays on multiple relevant topics on Pillar Two is structured as follows: General Topics including the legal status of the GloBE Model Rules, their relation to tax treaties and EU Law, the GloBE STTR, the specifics of jurisdictional blending, their impact on tax competition and on tax incentives Scoping topics including the computation of the EUR 750 million threshold, the definition of MNE Group, territorial allocation of CEs and excluded entities Charging provisions, including GloBE ́s rule order and the impact of the GloBE Model Rules on minority shareholders Computation of GloBE Income and Loss, including contributions on the adjustment of permanent differences and specifics of dividends and equity gains for purposes of the base determination Computation of Adjusted Covered Taxes, including the notion of covered taxes, the recognition of temporal differences and the territorial allocation of covered taxes Top-up Tax computation including contributions on the general correspondence of covered taxes and GloBE Income, the Substance-Based Income Exclusion, the specifics of Investment and Minority-Owned Constituent Entities and the general role of the QDMTT within the framework of Pillar Two Selected topics on the administration of GloBE, e.g., Safe Harbors and the identification of the taxpayer within the framework of Pillar Two