imported>Doug Williamson |
imported>Doug Williamson |
| Line 1: |
Line 1: |
| ''Tax - profit shifting - Global Minimum Tax - Organisation for Economic Co-operation and Development (OECD) - Pillar 2.''
| | 1. |
|
| |
|
| (IIR). | | (JV). |
|
| |
|
| The Income Inclusion Rule is the primary calculation mechanism to ensure that large multinational entities are subject to a global minimum tax rate.
| | A contractual arrangement where two or more parties undertake an economic activity which is subject to joint control. |
|
| |
|
| The tax jurisdiction of the ultimate parent collects top-up tax in relation to foreign subsidiaries with effective tax rates below the minimum rate of 15%.
| |
|
| |
|
| | 2. |
|
| |
|
| :<span style="color:#4B0082">'''''Two interlocking rules'''''</span>
| | ''Financial reporting''. |
|
| |
|
| :"The [Pillar 2] provisions are made up of the following two interlocking rules:
| | A joint arrangement whereby the parties that have joint control of the arrangement have rights to the net assets of the arrangement. |
|
| |
|
| :• Income Inclusion Rule (IIR): this is the primary calculation mechanism. The ultimate parent territory collects the top-up tax associated with foreign subsidiaries with an effective tax rate (ETR) below 15%.
| |
|
| |
| :• Undertaxed Payments Rule (UTPR): subsidiary territories collect the top-up tax in respect of a low-taxed overseas sister or parent company, where it is not captured by a parent territory IIR."
| |
|
| |
| :''Graham Robinson, international tax and treasury partner PwC & Iain McDonald international tax and treasury director PwC - The Treasurer, Issue 4 2022 - December 2022, p40.''
| |
|
| |
|
|
| |
|
| == See also == | | == See also == |
| | * [[Associate]] |
| | * [[IFRS 11]] |
| | * [[Joint control]] |
| | * [[Joint operation]] |
| | * [[Proportionate consolidation]] |
|
| |
|
| * [[Base erosion and profit shifting]] (BEPS)
| |
| * [[Corporation Tax]]
| |
| * [[Effective tax rate]] (ETR)
| |
| * [[Global Anti-Base Erosion Rules]] (GloBE)
| |
| * [[Income Tax]]
| |
| * [[Multinational corporation/company]]
| |
| * [[Nexus rule]]
| |
| * [[Organisation for Economic Co-operation and Development]] (OECD)
| |
| * [[Parent company]]
| |
| * [[Pillar 1]]
| |
| * [[Pillar 2]]
| |
| * [[Profit shifting]]
| |
| * [[Regime]]
| |
| * [[Sister company]]
| |
| * [[Subject To Tax Rule]]
| |
| * [[Tax ]]
| |
| * [[Tax avoidance]]
| |
| * [[Tax compliance]]
| |
| * [[Tax evasion]]
| |
| * [[Tax haven]]
| |
| * [[Tax rate]]
| |
| * [[Top-up tax]]
| |
| * [[Transfer pricing]]
| |
| * [[Undertaxed Payments Rule]] (UTPR)
| |
|
| |
|
| |
| ==External links==
| |
| *[https://www.oecd.org/tax/beps/tax-challenges-arising-from-the-digitalisation-of-the-economy-global-anti-base-erosion-model-rules-pillar-two.htm OECD - Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two) - Commentary]
| |
| *[https://www.oecd.org/tax/beps/pillar-two-model-rules-in-a-nutshell.pdf Pillar Two rules in a nutshell - OECD]
| |
|
| |
| [[Category:Accounting,_tax_and_regulation]]
| |
| [[Category:The_business_context]]
| |
| [[Category:Corporate_finance]] | | [[Category:Corporate_finance]] |
| [[Category:Long_term_funding]]
| |
| [[Category:Identify_and_assess_risks]]
| |
| [[Category:Manage_risks]]
| |
| [[Category:Risk_frameworks]]
| |
| [[Category:Risk_reporting]]
| |
