Annotations on the OECD Global Anti-Base Erosion Model Rules (Pillar 2)

Annotations on the OECD Global Anti-Base Erosion Model Rules (Pillar 2) is a first-of-its-kind book that provides an in-depth survey of the implications of Pillar 2 of the OECD Global Anti-Base Erosion Model 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. Although still under development, Pillar 2 Rules already pose significant challenges for taxation authorities globally. Intended to establish a floor in the possibilities for countries to compete for corporate investment with each other in corporate income taxation, the Pillar 2 Rules arising from the OECD/G20 Inclusive Framework have been agreed on by 140 countries.

What’s in this book:

Based on 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

How this will help you:

It has been estimated that the GloBE reform would produce a global additional tax revenue of USD 200 billion annually. Thus, taxation authorities, tax practitioners, and multinational corporate counsel must become as aware as possible of the intricacies of the Pillar 2 Rules. For this reason, this detailed discussion and analysis will be greatly appreciated by taxation professionals worldwide.