KPMG report: New guidance on Pillar Two rules, initial observations and analysis
A KPMG report that provides initial observations and analysis on Pillar Two rules
A KPMG report that provides initial observations and analysis on Pillar Two rules
The OECD/G20 Inclusive Framework on BEPS on 17 July 2023 released new guidance on the Pillar Two rules. Read TaxNewsFlash
- A Subject to Tax Rule (STTR) [PDF 2.2 MB] that is a tax treaty-based rule that allows for the levying of additional tax on several categories of related party payments not subject to a tax rate of at least 9% in the country of residence. The new Inclusive Framework (IF) document sets out a design for the STTR provision and commentary on its operation. Read a July 2023 report [PDF 174 KB] prepared by KPMG LLP that provides initial observations and analysis of the new STTR document.
- Additional guidance on global anti-base erosion (GloBE) items:
- The GloBE Information Return [PDF 1.3 MB] that comprises 28 pages and about 480 data points covering all areas of the GloBE rules. Read a July 2023 report [PDF 256 KB] prepared by KPMG LLP that provides initial observations of the GloBE Information Return.
- Further Administrative Guidance [PDF 1 MB] that adds to the expanding body of guidance that has been approved by the IF on the GloBE rules, including the Model Rules (released in December 2021), Commentary (released in March 2022), and Safe Harbors [PDF 459 KB] (released in December 2022). The new administrative guidance covers 26 items in 111 pages and aims to clarify or simplify the application of the GloBE rules. Read a July 2023 report [PDF 325 KB] prepared by KPMG LLP that provides initial observations and analysis of the new administrative guidance.
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