The ninth session of series on Pillar 2 GloBE model rules focuses on the challenges posed by complex structures and reorganisations and how they impact Global Anti-Base Erosion (GloBE) income. The GloBE rules apply to multi-national enterprise (MNE) groups that...

The seventh session of our 10-part series on Pillar 2 GloBE model rules focuses on how elections can help align GloBE income to mirror local tax treatment and iron out issues that could skew the effective tax rate (ETR). There...

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...

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...

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,...

Over the last decade, the Organisation for Economic Co-operation and Development (OECD) and the European Union (EU) have made significant developments regarding tax transparency regimes and the exchange of information between tax authorities.  However, these developments are being taken further...

Pillar 2, which is the Global Anti-Base Erosion Rules (GloBE) minimum tax project, and the BEFIT initiatives are considered likely to reduce some tax planning opportunities respectively at worldwide and EU levels, and thus reduce the need to address them...

The OECD two-pillar approach In October 2021, the OECD’s 137 Inclusive Framework members agreed to adopt a two-pillar approach to address the tax challenges of the digital economy. Pillar I provides for new profit allocation and nexus rules for MNEs...

As of 13 July, 132 of 139 jurisdictions (including Bermuda, Cayman Islands, BVI, Switzerland, and the Bahamas) agreed to the OECD Pillar 1 and 2 proposals as refined by the US initiative.  The seven that did not were: Ireland, Estonia,...