Business / Commercial Law Taxation Law

Pillar Two of the Inclusive Framework on BEPS: A Problem-solving Approach

By Carlo Garbarino
Edward Elgar Publishing September 2024

Specifications

ISBN-13
9781035312375
Publisher
Edward Elgar Publishing
Publication
September 2024
Format
Hardback
Jurisdiction
U.K. ? Countri(es) for reference only

Details

Adopting a practical problem-solving approach, this book critically analyses the recent OECD Global Anti-Base Erosion Model Rules that have been adopted to address the tax challenges arising from the digitalisation of the economy. It provides a clear and systematic explanation of Pillar Two and the OECD policies, which are now being implemented in a variety of national tax systems.

Key Features:

  • Exploration of the scope of the GloBE Rules
  • Accessible explanations of technical jargon accompanied by examples
  • Focus on key concepts of GloBE income or loss and adjusted covered taxes
  • Concise descriptions of each area of OECD policies on the global minimum tax
  • Investigation into the mechanism currently being used to apply the global minimum tax
  • Examination of domestic qualified minimum taxes that align with OECD standard, tax neutrality and distribution regimes

This thorough and authoritative guide is an indispensable resource for tax lawyers, tax managers of multinational firms, tax professionals, and tax administrations and international organisations. The book’s expert analysis of complex tax reporting procedures for multinational companies is also beneficial to academics and researchers of corporate tax and international taxation.

Table of Contents

Introduction: The policies of the Inclusive Framework on Pillar Two and the operation of the global minimum tax within the context of MNEs 1
Carlo Garbarino
1.
Perimeter of GloBE rules 21
Sebastiano Garufi Giuliani
2.
Individual GloBE income or loss 61
Christos A. Theophilou and Artemis Loucaidou
3.
Taxes paid by the group 125
Pitambar Das
4.
Effective tax rates and the minimum rate 166
Amedeo Rizzo and Pitambar Das
5.
Mechanism to apply the minimum tax 194
Giovanni Rolle
6.
Domestic qualified minimum taxes 228
Gergely Czoboly
7.
Tax neutrality and distribution regimes 287
Pablo A. Hernández González-Barreda
8.
Dynamics of group perimeter 333
Giulio Allevato
9.
Administration and transition rules 354
Stefano Castagna
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