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Pris: 2516 SEK exkl. moms  |  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.
Table Of Contents
Editors
Contributors
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
Marco Busia
CHAPTER 10
Differences Between the OECD’s GloBE Model Rules and the EU’s GloBE Directive
Rita Szudoczky & Valentin Bendlinger
CHAPTER 11
Pillar 2 and GILTI: Coexistence, Conformity or Fracture?
Mindy Herzfeld
Index | | |
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