Key to the topic of Pillar Two are elections that are specific to certain entity types and tax regimes, each with sector- and transaction-specific considerations. How should in-scope Multinational Enterprise (MNE) groups identify these elections and make smart and strategic decisions to mitigate their top-up tax exposure in line with Pillar Two policy objectives?
As momentum grows around a Safe Harbour potentially exempting US-parented groups from the Income Inclusion Rule and Undertaxed Profits Rule, key questions arise: What will this exemption look like, and how does it compare to the Permanent Safe Harbour for all in-scope MNE groups?
Join our upcoming webinar as we delve into these critical developments and their implications for businesses in the global tax landscape.
Webinar highlights:
- Pillar Two elections deeper dive: Discover which specific elections apply to certain entities (e.g., Investment Entities, Excluded Entities) and elections which may be more relevant to certain industries (e.g., Aggregate Asset Gain election for property disposals) and under what circumstances these elections could apply.
- Permanent Safe Harbour (US/Non-US Parented Groups): Explore how the Safe Harbour for US-Parented Groups will work, when will it likely take effect, and how it compares against the Permanent Safe Harbour intended for all in-scope MNE Groups.
- Pillar Two top-up tax and tax provisioning: Get the answers to key FAQs on Pillar Two top-up tax and provisioning, including the impact of deferred tax liabilities under the 5-year recapture rule and their interaction with year-end tax provisions.
Be in Front of the evolving tax landscape and ensure compliance as you prepare your organisation for Pillar Two implementation.
