imported>Doug Williamson |
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| ''Tax - profit shifting - Global Minimum Tax - Organisation for Economic Co-operation and Development (OECD) - Pillar 2.'' | | 1. ''Working effectively with others - performance.'' |
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| (IIR).
| | A peer is an individual of similar seniority or an organisation operating in the same sector, usually of similar size. |
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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%.
| | 2. ''Corporate performance.''. |
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| | Abbreviation for peer company or business. |
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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:
| | ==See also== |
| | | *[[Coach]] |
| :• 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%.
| | *[[Coaching]] |
| | | *[[Peer coaching]] |
| :• 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."
| | *[[Peer company]] |
| | | * [[Peer-to-peer]] |
| :''Graham Robinson, international tax and treasury partner PwC & Iain McDonald international tax and treasury director PwC - The Treasurer, Issue 4 2022 - December 2022, p40.''
| | *[[Peer review]] |
| | | *[[Performance]] |
| | | *[[Performance management]] |
| == See also == | | *[[Skills and performance coaching]] |
| | | *[[Working effectively with others]] |
| * [[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]]
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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]] | | [[Category:Accounting,_tax_and_regulation]] |
| [[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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