Since the Inclusive Framework mandated by the G20 finance ministers could not agree on a final recommendation under BEPS Action 1 in 2015 addressing the tax challenges of the digital economy, several other proposals have been introduced. While some proposals are addressing the digital economy itself (Pillar One), another proposal focuses on encountering remaining BEPS issues left after the implementation of the BEPS minimum standards (Pillar Two).
The idea of Pillar Two is to prevent harmful tax competition by introducing a global minimum taxation (GloBE), thus discouraging multinational enterprises to establish activities in jurisdictions only for tax purposes. The two main instruments to achieve this goal show several similarities to the US GILTI and BEAT initiatives; however, the OECD is discussing a number of deviations and simplifications to roll out this approach on a global level.
This webinar provides a brief introduction into the design principles of GloBE and outlines the main challenges and chances of this proposal. It will cover:
• The genesis of Pillar 2
• The income inclusion rule
• Undertaxed payment rules
• The way forward
To register, please click here.