For in-scope multinational enterprise groups with a 31 December year-end, the first major Pillar Two compliance milestone has now passed. Scrutiny is set to intensify as tax authorities have received their first GloBE Information Returns (GIRs) and top-up tax returns for FY2024.
What comes next?
As tax authorities begin reviewing and assessing these filings, differences in interpretation and limited administrative guidance may lead to disputes on key issues such as entity classification, taxing rights, and the treatment of pre-regime taxes. Could these disputes result in double taxation? If so, what options are available to help prevent or resolve them?
Join our upcoming webinar for practical insights into the emerging Pillar Two controversy landscape, potential dispute resolution pathways, and the steps businesses can take now to prepare.
What we’ll cover:
- FY2024 GIR and top-up tax returns: Potential sections within the GIR, as well as top-up tax returns, which may be picked up by the tax authorities for review, and how they could give rise to other related queries such as Country-by-Country Reporting (CbCR).
- Potential interpretation issues giving rise to disputes: Common scenarios such as the treatment of pre-regime tax expenses, taxing rights for jurisdictions with Qualified Domestic Minimum Top-up Tax Safe Harbour, entity classification, Transitional CbCR Safe Harbour calculations, GloBE Loss Election, etc.
- Working towards tax certainty: The Organisation for Economic Co-operation and Development’s proposed GloBE Coordination Mechanism, what it entails, and the dispute prevention process likely under development.
- Dispute Resolution Mechanisms: The existing Multilateral Agreement Procedure framework and emerging avenues for Pillar Two dispute prevention and resolution.
