Globe Pillar 2

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The Pillar Two Global Minimum Tax

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Author : Werner Haslehner
language : en
Publisher: Edward Elgar Publishing
Release Date : 2024-08-06

The Pillar Two Global Minimum Tax written by Werner Haslehner and has been published by Edward Elgar Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-08-06 with Law categories.

Bringing together leading experts in the field of tax law, this book comprehensively analyses the new global minimum taxation regime for multinational companies. Not only does it consider this unprecedented diplomatic achievement in its historic, economic and political context, but the book also explores the intricate technical detail of the GloBE model rules.

The Global Minimum Tax Selected Issues On Pillar Two

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Author : Valentin Bendlinger
language : en
Publisher: Linde Verlag GmbH
Release Date : 2024-10-18

The Global Minimum Tax Selected Issues On Pillar Two written by Valentin Bendlinger and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-10-18 with Law categories.

Global Minimum Tax at a glance The OECD ́s Global Minimum Tax is amongst the most discussed topics in the recent international tax law debate. The book provides for more than 25 individual but co-ordinated essays on multiple relevant topics on Pillar Two is structured as follows: General Topics including the legal status of the GloBE Model Rules, their relation to tax treaties and EU Law, the GloBE STTR, the specifics of jurisdictional blending, their impact on tax competition and on tax incentives Scoping topics including the computation of the EUR 750 million threshold, the definition of MNE Group, territorial allocation of CEs and excluded entities Charging provisions, including GloBE ́s rule order and the impact of the GloBE Model Rules on minority shareholders Computation of GloBE Income and Loss, including contributions on the adjustment of permanent differences and specifics of dividends and equity gains for purposes of the base determination Computation of Adjusted Covered Taxes, including the notion of covered taxes, the recognition of temporal differences and the territorial allocation of covered taxes Top-up Tax computation including contributions on the general correspondence of covered taxes and GloBE Income, the Substance-Based Income Exclusion, the specifics of Investment and Minority-Owned Constituent Entities and the general role of the QDMTT within the framework of Pillar Two Selected topics on the administration of GloBE, e.g., Safe Harbors and the identification of the taxpayer within the framework of Pillar Two

Globe Rules Made Easy

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Author : Kuldeep Sharma
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2022-12-09

Globe Rules Made Easy written by Kuldeep Sharma and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-12-09 with Law categories.

Worldwide implementation of the OECD’s Global Anti-Base Erosion Rules (GloBE Rules), published in December 2021, promises to strike a powerful blow at the tax avoidance rampantly indulged in by many multinational corporations since global minimum tax rate of 15% in all countries is expected to curb shifting of profits from higher tax jurisdiction to lower tax jurisdiction or tax havens. As Inclusive Framework (IF) Member jurisdictions prepare to implement legislation, the tax law community worldwide can turn to this extraordinarily practical, self-contained book for a complete understanding of the background and attributes of the Rules. The book includes such features as the following: text of each of the Rules’ ten chapters (including all forty-nine articles) along with both summary and detailed description; explanations of the Commentary and Illustrative Examples released by the OECD in March 2022; numerous flowcharts, tables, boxes, illustrations, and figures; elaborate technical discussions amidst specific policy considerations; analysis of IF Member jurisdictions regarding key parameters with suitable recommendations; ‘GloBE Rules at a Glance’ checklist encapsulating the features and application of the Rules in the form of FAQs; and implementation processes under way in ten representative jurisdictions. The various publications and releases by the OECD up to 31 May 2022 are considered and duly explained. In the struggle to curb harmful tax competition and aggressive tax planning, it is possible that the GloBE Rules will at last succeed in creating a level playing field in the realm of taxation. And given that OECD guidance and tax expert analysis may not suffice to fully comprehend the complexity of the Rules, this book will prove of enormous value among a wide array of stakeholders, including taxation authorities, tax advisors and lawyers, and academics. Also, multinational enterprises will get enough information to derive maximum benefits in terms of their preparedness, readiness, and responses to implementation of the Rules.

Annotations On The Oecd Global Anti Base Erosion Model Rules Pillar 2

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Author : Dennis Weber
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2024-09-16

Annotations On The Oecd Global Anti Base Erosion Model Rules Pillar 2 written by Dennis Weber and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-09-16 with Law categories.

Although still under development, Pillar 2 of the OECD Global Anti-Base Erosion Model Rules is already posing significant challenges for taxation authorities worldwide. Intended to establish a floor in the possibilities for countries to compete for corporate investment with each other in the field of corporate income taxation, the Pillar 2 Rules arising from the OECD/G20 Inclusive Framework have been agreed on by 140 countries. This book provides the first in-depth survey of the implications of the 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. Undergirded by 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. It has been estimated that the GloBE reform would produce a worldwide additional tax revenue of USD 200 billion annually. It has thus become imperative for taxation authorities, tax practitioners, and multinational corporate counsel to become as aware as possible of the intricacies of the Pillar 2 Rules, and for this reason, this detailed discussion and analysis will be greatly appreciated by taxation professionals worldwide.

Taxing Profit In A Global Economy

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Author : Michael P. Devereux
language : en
Publisher: Oxford University Press
Release Date : 2020-09-29

Taxing Profit In A Global Economy written by Michael P. Devereux and has been published by Oxford University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-09-29 with Business & Economics categories.

1:Introduction 2:Key issues in taxing profit 3:The current international tax system 4:Fundamental reform options 5:Basic choices in considering reform 6:Residual profit allocation by income 7:Destination-based cash flow taxation.

Standard For Automatic Exchange Of Financial Account Information In Tax Matters Second Edition

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2017-03-27

Standard For Automatic Exchange Of Financial Account Information In Tax Matters Second Edition written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-03-27 with categories.

This publication contains the following four parts: A model Competent Authority Agreement (CAA) for the automatic exchange of CRS information; the Common Reporting Standard; the Commentaries on the CAA and the CRS; and the CRS XML Schema User Guide.

Harmful Tax Competition An Emerging Global Issue

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 1998-05-19

Harmful Tax Competition An Emerging Global Issue written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 1998-05-19 with categories.

Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.

International Corporate Tax Avoidance A Review Of The Channels Magnitudes And Blind Spots

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Author : Sebastian Beer
language : en
Publisher: International Monetary Fund
Release Date : 2018-07-23

International Corporate Tax Avoidance A Review Of The Channels Magnitudes And Blind Spots written by Sebastian Beer and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-07-23 with Business & Economics categories.

This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.

Oecd G20 Base Erosion And Profit Shifting Project Tax Challenges Arising From Digitalisation Interim Report 2018 Inclusive Framework On Beps

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2018-03-16

Oecd G20 Base Erosion And Profit Shifting Project Tax Challenges Arising From Digitalisation Interim Report 2018 Inclusive Framework On Beps written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-03-16 with categories.

This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy.

Complexity And Sustainability In Megaprojects

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Author : Franca Cantoni
language : en
Publisher: Springer Nature
Release Date : 2024-05-20

Complexity And Sustainability In Megaprojects written by Franca Cantoni and has been published by Springer Nature this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-05-20 with Science categories.

This book showcases the discussion about megaprojects carried out at the MeRIT (Megaproject Research Interdisciplinary Team) workshop 2023: the crisis, discontinuity, rising prices, and supply chains disruption force radical reflection for those involved in megaprojects. It raises a modern-day challenge, the creation of value for stakeholders. Indeed, the aim of the volume is to encourage readers to think more broadly, articulately and less stringently than the mainstream claims. There is a need to design, implement, and manage megaprojects by abandoning the old paradigm that leveraged solely on time and cost. We need to move beyond that by going to explore the value generated, the positive impact on people, communities and territories. Economic, social and environmental sustainability takes on a new and broader articulation: issues of the circular economy applied to megaprojects are addressed and ample space is ensured for the inclusion of social needs in current practices.