The OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) released further technical guidance to assist governments with implementation of the global minimum tax under Pillar Two and a statement on the timeline of the Multilateral Convention (MLC) under Pillar One.
The Agreed Administrative Guidance for the Pillar Two GloBE Rules (December 2023) supplements the Commentary to the Global Anti-Base Erosion Model Rules in order to clarify their application, including guidance on the application of the Transitional Country-by-Country Reporting Safe Harbour and a mechanism for allocating taxes arising in a Blended Controlled Foreign Corporation (CFC) Tax Regime when some of the jurisdictions the MNE operates in are eligible for the safe harbour. The Inclusive Framework also released a statement updating the timeline to finalise the text of the MLC to implement the coordinated reallocation of taxing rights over the profits of the world’s largest and most profitable companies (Amount A of Pillar One). The statement expresses the continued and strong commitment of Inclusive Framework delegates to resolve the outstanding issues, achieve a consensus-based solution and finalise the text of the MLC as swiftly as possible. Comments are closed.
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March 2024
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