KPMG report: Pillar Two implementation package, initial observations and analysis

Implementation package related to the Pillar Two global anti-base erosion (GloBE) rules

Initial observations and analysis

The OECD/G20 Inclusive Framework on BEPS on 20 December 2022 released an implementation package related to the Pillar Two global anti-base erosion (GloBE) rules, which provide a coordinated system to ensure that multinational enterprises (MNEs) with revenues above €750 million pay at least an effective rate of 15% on the income arising in each of the jurisdictions in which they operate.

The package includes three documents:

The safe harbors and penalty relief document includes a transitional country-by-country (CbC) reporting safe harbor that has already been agreed by the Inclusive Framework and a framework for the development of a potential permanent safe harbor. Not included in the package is administrative guidance on many outstanding technical issues; such guidance is expected to be issued in the future on a rolling basis, with the first tranche expected in early 2023. Work is also underway on the subject to tax rule and the implementing multilateral instrument.
 

Read a December 2022 report [PDF 216 KB] prepared by KPMG LLP that provides observations and analysis of the implementation package

In addition, read a December 2022 report [PDF 138 KB] prepared by KPMG professionals that compiles in summary form the announcements made by various countries on implementation of the GloBE rules

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