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Inclusive Framework releases | 17 July 2023
On 17 July 2023, the Inclusive Framework released four main documents comprising approximately 280 pages. These include the release of the Consultation Document on Amount B of Pillar 1, and a final report on the Subject to Tax Rule, an outline of the GloBE Information Return and the second set of Administrative Guidance.
KPMG has prepared releases in relation to each of these items which are available below. In addition, an Outcome Statement was released on 11 July 20231.
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The Outcome Statement indicates that the Inclusive Framework has delivered a text for a Multilateral Convention (MLC) which facilitates the allocation of a portion of profits for certain MNEs above a €20 billion turnover threshold to market jurisdictions that reach particular thresholds. The release states that there will be a deferral of newly enacted DSTs and similar relevant measures until 31 December 2024 (or earlier if an MLC comes into force earlier) providing at least 30 jurisdictions accounting for 60% of the in scope Ultimate Parent Entities sign-up to the MLC before the end of 2023.
There is a significant amount of material for MNEs to digest and apply to their groups. This is a mix of new beneficial simplifications and additional complexity for MNEs to navigate. It is very clear in terms of scale this is the most dramatic set of new rules the realm of international tax has seen.
Now is the time for MNEs to embrace their GloBE projects. The release of the GIR should be considered a wake-up call and shows the task ahead is formidable.
A global view on tax policy
With tax policy developments around the world quickly evolving, multinational organizations need to take a global view of the implications for their businesses, while also keeping an eye on specific jurisdictional considerations that may have an impact.
KPMG’s Tax Policy Leadership Group includes leading thinkers from around the world who convene weekly to discuss the latest issues in tax policy. The group engages with countries and jurisdictions across the organization and in the external market, and regularly publishes perspectives on new developments and the potential impacts and key considerations for multinational organizations.
Explore this page to view KPMG professionals’ responses to the latest OECD developments, as well as insights into the latest tax policy developments taking place around the world.
View KPMG responses to the latest tax policy developments
Insights: Tax policy
Video insights: Tax policy
- 1Source: https://www.oecd.org/tax/beps/outcome-statement-on-the-two-pillar-solution-to-address-the-tax-challenges-arising-from-the-digitalisation-of-the-economy-july-2023.pdf .
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