imported>Doug Williamson |
imported>Administrator |
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| ''Tax - profit shifting - Global Minimum Tax - Organisation for Economic Co-operation and Development (OECD) - Pillar 2.'' | | ''Economics''. |
| | | The percentage change in quantity demanded divided by the percentage change in income. |
| (IIR).
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| The Income Inclusion Rule is the primary calculation mechanism to ensure that large multinational entities are subject to a global minimum tax rate. | |
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| 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%.
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| :<span style="color:#4B0082">'''''Two interlocking rules'''''</span>
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| :"The [Pillar 2] provisions are made up of the following two interlocking rules:
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| :• 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%.
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| :• 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."
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| :''Graham Robinson, international tax and treasury partner PwC & Iain McDonald international tax and treasury director PwC - The Treasurer, Issue 4 2022 - December 2022, p40.''
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| == See also == | | == See also == |
| | * [[Elasticity]] |
| | * [[Necessity]] |
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| * [[Base erosion and profit shifting]] (BEPS)
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| * [[Corporation Tax]]
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| * [[Effective tax rate]] (ETR)
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| * [[Global Anti-Base Erosion Rules]] (GloBE)
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| * [[Income Tax]]
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| * [[Multinational corporation/company]]
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| * [[Nexus rule]]
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| * [[Organisation for Economic Co-operation and Development]] (OECD)
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| * [[Parent company]]
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| * [[Pillar 1]]
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| * [[Pillar 2]]
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| * [[Profit shifting]]
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| * [[Regime]]
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| * [[Sister company]]
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| * [[Subject To Tax Rule]]
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| * [[Tax ]]
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| * [[Tax avoidance]]
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| * [[Tax compliance]]
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| * [[Tax evasion]]
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| * [[Tax haven]]
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| * [[Tax rate]]
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| * [[Top-up Tax]]
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| * [[Transfer pricing]]
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| * [[Undertaxed Payments Rule]] (UTPR)
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| ==External links==
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| *[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]
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| *[https://www.oecd.org/tax/beps/pillar-two-model-rules-in-a-nutshell.pdf Pillar Two rules in a nutshell - OECD]
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| [[Category:Accounting,_tax_and_regulation]]
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| [[Category:The_business_context]]
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| [[Category:Corporate_finance]]
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| [[Category:Long_term_funding]]
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| [[Category:Identify_and_assess_risks]]
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| [[Category:Manage_risks]]
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| [[Category:Risk_frameworks]]
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| [[Category:Risk_reporting]]
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