A KPMG report that provides initial observations and analysis on the new guidance and describes additional Pillar Two guidance expected this year.
The OECD/G20 Inclusive Framework (IF) on June 17, 2024, released its fourth tranche of administrative guidance on the Pillar Two global anti-base erosion (GloBE) model rules. Read TaxNewsFlash
The guidance provides detailed recapture rules for deferred tax liabilities, new rules on deferred tax assets and liabilities where there are divergences between GloBE rules and accounting carrying values, the allocation of cross-border current and deferred taxes, the allocation of profits and taxes in structures involving flow-through entities, and the treatment of securitization vehicles.
Read a June 2024 report prepared by KPMG LLP that provides initial observations and analysis on the new guidance and describes additional Pillar Two guidance expected this year.