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,...

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...