In point and Income Inclusion Rule: Difference between pages
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'' | ''Tax - profit shifting - Global Minimum Tax - Organisation for Economic Co-operation and Development (OECD) - Pillar 2.'' | ||
(IIR). | |||
The Income Inclusion Rule is the primary calculation mechanism to ensure that large multinational entities are subject to a global minimum tax rate. | |||
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%. | |||
:<span style="color:#4B0082">'''''Two interlocking rules'''''</span> | |||
:"The [Pillar 2] provisions are made up of the following two interlocking rules: | |||
:• 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 == | ||
* [[Base erosion and profit shifting]] (BEPS) | |||
* [[Corporation Tax]] | * [[Corporation Tax]] | ||
* [[ | * [[Domestic Minimum Tax]] | ||
* [[Effective tax rate]] (ETR) | |||
* [[Global Anti-Base Erosion Rules]] (GloBE) | |||
* [[Income Tax]] | * [[Income Tax]] | ||
* [[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:Long_term_funding]] | |||
[[Category:Identify_and_assess_risks]] | |||
[[Category:Manage_risks]] | |||
[[Category:Risk_frameworks]] | |||
[[Category:Risk_reporting]] |
Revision as of 21:39, 3 December 2022
Tax - profit shifting - Global Minimum Tax - Organisation for Economic Co-operation and Development (OECD) - Pillar 2.
(IIR).
The Income Inclusion Rule is the primary calculation mechanism to ensure that large multinational entities are subject to a global minimum tax rate.
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%.
- Two interlocking rules
- "The [Pillar 2] provisions are made up of the following two interlocking rules:
- • 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
- Base erosion and profit shifting (BEPS)
- Corporation Tax
- Domestic Minimum 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)