Hardback
Pillar Two of the Inclusive Framework on BEPS
A Problem-solving Approach
9781035312375 Edward Elgar Publishing
Adopting a practical problem-solving approach, this book critically analyses the recent OECD Global Anti-Base Erosion Model Rules that have been adopted to address the tax challenges arising from the digitalisation of the economy. It provides a clear and systematic explanation of Pillar Two and the OECD policies, which are now being implemented in a variety of national tax systems.
More Information
Critical Acclaim
Contents
More Information
Adopting a practical problem-solving approach, this book critically analyses the recent OECD Global Anti-Base Erosion Model Rules that have been adopted to address the tax challenges arising from the digitalisation of the economy. It provides a clear and systematic explanation of Pillar Two and the OECD policies, which are now being implemented in a variety of national tax systems.
Key Features:
• Exploration of the scope of the GloBE Rules
• Accessible explanations of technical jargon accompanied by examples
• Focus on key concepts of GloBE Income or Loss and Adjusted Covered Taxes
• Concise descriptions of each area of OECD policies on the global minimum tax
• Investigation into the mechanism currently being used to apply the global minimum tax
• Examination of domestic qualified minimum taxes that align with OECD standards
• Analysis of tax neutrality and distribution regimes
This thorough and authoritative guide is an indispensable resource for tax lawyers, tax managers of multinational firms, tax professionals, and tax administrations and international organisations. The book’s expert analysis of complex tax reporting procedures for multinational companies is also beneficial to academics and researchers of corporate tax and international taxation.
Key Features:
• Exploration of the scope of the GloBE Rules
• Accessible explanations of technical jargon accompanied by examples
• Focus on key concepts of GloBE Income or Loss and Adjusted Covered Taxes
• Concise descriptions of each area of OECD policies on the global minimum tax
• Investigation into the mechanism currently being used to apply the global minimum tax
• Examination of domestic qualified minimum taxes that align with OECD standards
• Analysis of tax neutrality and distribution regimes
This thorough and authoritative guide is an indispensable resource for tax lawyers, tax managers of multinational firms, tax professionals, and tax administrations and international organisations. The book’s expert analysis of complex tax reporting procedures for multinational companies is also beneficial to academics and researchers of corporate tax and international taxation.
Critical Acclaim
‘This book offers a comprehensive and clear analysis of the GloBE Model Rules. With constant references to the Inclusive Framework’s Commentary and Administrative Guidances, this volume will be of great help for tax executives of multinational groups and for advisers seeking to implement the GloBE Rules and understand their logic.’
– Daniel Gutmann, Sorbonne University, France
– Daniel Gutmann, Sorbonne University, France
Contents
Contents
Introduction: The policies of the Inclusive Framework on Pillar Two and the operation of
the global minimum tax within the context of MNEs 1
Carlo Garbarino
1 Perimeter of GloBE rules 21
Sebastiano Garufi Giuliani
2 Individual GloBE income or loss 61
Christos A. Theophilou and Artemis Loucaidou
3 Taxes paid by the group 125
Pitambar Das
4 Effective tax rates and the minimum rate 166
Amedeo Rizzo and Pitambar Das
5 Mechanism to apply the minimum tax 194
Giovanni Rolle
6 Domestic qualified minimum taxes 228
Gergely Czoboly
7 Tax neutrality and distribution regimes 287
Pablo A. Hernández González-Barreda
8 Dynamics of group perimeter 333
Giulio Allevato
9 Administration and transition rules 354
Stefano Castagna
Introduction: The policies of the Inclusive Framework on Pillar Two and the operation of
the global minimum tax within the context of MNEs 1
Carlo Garbarino
1 Perimeter of GloBE rules 21
Sebastiano Garufi Giuliani
2 Individual GloBE income or loss 61
Christos A. Theophilou and Artemis Loucaidou
3 Taxes paid by the group 125
Pitambar Das
4 Effective tax rates and the minimum rate 166
Amedeo Rizzo and Pitambar Das
5 Mechanism to apply the minimum tax 194
Giovanni Rolle
6 Domestic qualified minimum taxes 228
Gergely Czoboly
7 Tax neutrality and distribution regimes 287
Pablo A. Hernández González-Barreda
8 Dynamics of group perimeter 333
Giulio Allevato
9 Administration and transition rules 354
Stefano Castagna
