The sixth article of our series on Pillar 2 GloBE model rules focuses on how to identify the key principles of adjusted covered taxes. Adjusted covered taxes is the numerator in the formula for determining the effective tax rate under...

Continuing our technical series on Pillar 2 GloBE, article five aims to assess how to determine your Financial Accounting Net Income or Loss (FANIL) by applying the relevant OECD-listed adjustments, alongside a brief overview of other additional adjustments. As discussed...

Continuing our technical series on Pillar 2 GloBE, this article aims to give an overview of the relationship between tax accounting and Pillar 2 GloBE. As well as highlighting basic accounting principles, the article will summarise issues relating to the...

In mid-February, the European Parliament (EP) voted by a majority to adopt the DAC9 legislative initiative. Now, the Council has reached a political agreement on the new EU directive. It acts as the sole legislator and will formally adopt DAC...

Following on from article two in our technical series on Pillar 2 GloBE, this article aims to peel away further layers of how the GloBE rules define MNE groups. In particular, we will look at some of the more complex...

One of the fundamental exercises for in-scope multinational enterprise (MNE) groups subject to Pillar 2 GloBE rules is to gain an in-depth knowledge of constituent entities (CEs) and permanent establishments (PEs) on a country-by-country basis. It is an important task...

The tax risks facing global organisations increase every year. In the EU alone, data from the European Commission shows there are around 900 double taxation disputes, estimated to be worth €10.5 billion.These figures are likely to continue increasing over the...

With the Organisation for Economic Co-operation and Development's (OECD) Pillar 2 Global anti-Base Erosion (GloBE) Rules now in play, understanding who, what, and how the regime will impact multinational enterprises (MNEs) is vital. With new OECD guidance being steadily released,...

Implementing a tax control framework (TCF) might sound like something only large multinational PLCs need to worry about. But for privately-owned businesses, a tax control framework also offers great opportunity. The risks a TCF guards against may be different in...

Sustainability challenges have become critical business imperatives in recent years. Regulators, stakeholders, investors, employees, customers - all expect a much higher degree of compliance and transparency. Businesses have got used to their performance in these areas being monitored and to...

Taxation has a key role for medium and large multinational companies in the process of developing a sustainable business model. Disclosure of complex tax information and transparency on profit allocation to group entities is key to this transformation process and...

There are two main drivers for organisations looking for advice around tax control frameworks (TCFs). Sometimes it is a proactive strategy to check their tax affairs are in good shape or to better understand any potential liability risks, for example....

Designed to ensure that multinational enterprises (MNEs) pay a global minimum tax (GMT) of 15% in each jurisdiction where they operate and generate income, the Pillar 2 global anti-base erosion (GloBE) rules are now a reality for in-scope MNEs and...

Developing and implementing a tax control framework (TCF) is a strategy being adopted by an increasing number of companies around the world.  There is no universal approach to developing a TCF. At Forvis Mazars, based on our wide experience working...

For Singapore and many other countries that have traditionally leant on financial incentives to attract foreign direct investments, the ambition of a 15% minimum global tax presented by Pillar 2 Global Anti-Base Erosion rules (GloBE) heralds a new challenge. While...

The Mexican Tax Administration Service (SAT) continues to innovate and invest in technology and artificial intelligence to make it easier and more efficient for taxpayers to file their monthly tax returns. On February 1st, 2024, The Mexican Tax Administration launched...

As in-scope organisations* embark on a new Pillar 2 Global Anti-Base Erosion (GloBE) journey, having a clearer understanding of how jurisdictions will enact the global minimum 15% tax rule is vital. Notably, while Pillar 2 GloBE sets out model rules...

Tax control frameworks are becoming increasingly common as companies seek to manage their taxation, compliance, and risk management obligations more effectively and efficiently. So, what is a tax control framework, and what are the benefits?  A tax control framework is...

The UK Spring Budget on 6 March 2024 was relatively measured in its tax policy decisions, despite a background of falling inflation and rising tax receipts.  Below are some areas of interest for globally mobile individuals, those with UK staff,...

Across the globe, an increasing number of companies are developing tax control frameworks to help them stay on top of their taxation, compliance and risk management obligations and objectives. These obligations are continually evolving, driven by a combination of both...

Several Mexican states had imposed ecological taxes in order to encourage certain industries to reduce their polluting emissions. In addition, green taxes have recently been imposed as a consequence of the warning issued by the Mexico Climate Initiative (MCI) that Mexico's...

As in-scope organisations* embark on a new Pillar 2 Global Anti-Base Erosion (GloBE) journey, having a clearer understanding of how jurisdictions will enact the global minimum 15% tax rule is vital. Notably, while Pillar 2 GloBE sets out model rules...

Background to Pillar 2 (GloBE) Part of the ongoing work of the OECD to combat tax avoidance and targeted at low tax jurisdictions, the Pillar 2 – GloBE rules will apply to large organisations (>€750m of global revenue) with each...

When the Austrian government – a coalition between the conservative People's Party and the Green Party – presented their government program for 2020-2024, an “eco-social tax reform” was one of the key elements. The most recent measure has been the...

The development of new web communication systems such as WEB3 is making it very difficult for tax authorities to trace taxable transactions.  However, measures proposed by the OECD and the European Union aim to provide a framework that will permit...

The European Parliament proposes significant amendments to the Anti-Tax Avoidance Directive, commonly known as ATAD3. ATAD3 seeks to prevent the misuse of shell companies for tax purposes. Compared to the initial draft Directive, the proposed amendments may provide relief for...

On 12 October 2022, the Mexican Government approved the Multilateral Instrument (MLI) related to the application rules for double taxation agreements (DTAs) to prevent Base Erosion and Profit Shifting (BEPS). The rules were published in the Official Gazette of the...

The European Commission (EC) launched an initiative on 6 July 2022 concerning the fight against tax evasion and aggressive tax planning. As a result, a public consultation introducing the Securing the Activity Framework of Enablers (SAFE) directive has now been...

Background To address harmful tax competition, the European Union (“EU”) requires Member States to refrain from introducing any new harmful tax measures and amend any laws or practices deemed to be harmful. Regarding non-EU jurisdictions, the EU has also evaluated...

The Diverted Profits Tax (DPT), or what the media have dubbed the Google tax, was introduced in 2015 to dissuade and counteract contrived arrangements used by large multinational groups that divert profits from the UK and erode the UK tax base.

Digital assets and cryptocurrencies continue to evolve by offering new services and products such as Decentralized Finance (DeFi) and non-fungible tokens (“NFTs”), but is tax legislation also keeping up to date with the ever-changing world of digital assets and cryptocurrencies? 

On 14 March 2022, the OECD published a comprehensive commentary and illustrative examples of how implementing the Global Anti-Base Erosion Model Rules (GloBE rules) could look. In this blog, we discuss the GloBE rules and examine how the rules apply...

The information regarding environmental taxes paid by an organisation, as well as the actions taken to mitigate the impact on the environment could be included in environmental, social, and governance (ESG) reporting. Environmental reporting in total is an important element...

A crucial number of Ukrainian companies (including subsidiaries of international enterprises) experienced negative business and financial impacts as a result of the Russian invasion of Ukraine which started on 24 February 2022. The urgent relocation of staff to other regions...

ATAD II is the EU translation of BEPS Action 2, the part which is focused on the ability of taxpayers to design situations of double non-taxation or heavily reduced taxation by exploiting hybrid mismatches. They apply to mismatches between the...

Mazars experts around the world deliver tailored services in audit, accounting, tax, financial advisory, consulting, and legal services. In Mexico, local experts have created a compliance dashboard with news items to help guide businesses as they navigate issues related to finance,...

When the UK finally left the EU ended on 31 December 2020, the application of provisions that have been beneficial to cross-border payments within the EU ceased, or will cease to apply. The elimination of withholding taxes, formerly part of...