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

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

Author: Stefano Grilli; Dennis Weber
Publisher: Kluwer Law International
ISBN: 9789403543161
Published In: September 2024
Format: Hardback
Jurisdiction: Netherlands ? Disclaimer:
Countri(es) stated herein are used as reference only

List Price: HKD 1,920.00

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Description
Contents

Details

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.

Preface and Acknowledgements

CHAPTER 1. Scope and Main Definitions

Maarten de Wilde

CHAPTER 2A. Charging Provisions

Marco Adda & Francesco Giuliano Parlatore

CHAPTER 2B. Charging Provisions: UTPR

Paolo Arginelli

CHAPTER 3A. Computation of GloBE Income or Loss

Giuseppe Francesco Patti

CHAPTER 3B. Computation of GloBE Income or Loss: International Shipping Income Exclusion (Article 3.3)

Ton Stevens

CHAPTER 3C. Computation of GloBE Income or Loss: Allocation of Income or Loss Between a Main Entity and a Permanent Establishment, and From a Flow-Through Entity

Kasper Dziurdz & Christoph Marchgraber

CHAPTER 4A. The Computation of Adjusted Covered Taxes

Dieter Bettens

CHAPTER 4B. The Computation of Adjusted Covered Taxes: Mechanism to Address Temporary Differences, the GloBE Loss Election, Post-filling Adjustments and Tax Rate Changes

Ana Paula Dourado & Leidson Rangel

CHAPTER 5. Computation of Effective Tax Rate and Top-Up Tax

Maarten de Wilde

CHAPTER 6. Corporate Restructuring and Holding Structures

Federica Pitrone

CHAPTER 7. Tax Neutrality and Distribution Regimes

Hein Vermeulen

CHAPTER 8A. Administration

Sigrid Hemels

CHAPTER 8B. Transitional CbCR Safe Harbours

Luca Bosco

CHAPTER 9. Transitional Rules