<< Go back to overview Next article>> Article 7.3. Eligible Distribution Tax Systems Article 7.3 allows certain distribution tax regimes to be accommodated within the structure of the GloBE Rules, subject to certain safeguards and recapture rules. A distribution tax regime is a tax system that generally imposes income [...]
<< Go back to overview Next article>> Article 7.2. Ultimate Parent Entity subject to Deductible Dividend Regime Article 7.2 contains a set of rules for UPEs that are subject to a Deductible Dividend Regime. These rules allow a deduction in the computation of the GloBE Income or Loss for [...]
<< Go back to overview Next article>> Article 7.1. Ultimate Parent Entity that is a Flow-through Entity A jurisdiction’s tax system may contain rules designed to achieve a single level of taxation on business income. While some jurisdictions may achieve this by adjusting the treatment of income in the [...]
<< Go back to overview Next article>> Article 6.5. Multi-Parented MNE Groups Article 6.5 covers the situation in which two or more Groups prepare Consolidated Financial Statements in which the financial performance of these Groups is presented as a single economic unit in accordance with a Dual-listed Arrangement or [...]
<< Go back to overview Next article>> Article 6.4. Joint Ventures A common business practice undertaken by MNE Groups is entering into joint ventures with third parties. Generally, for accounting purposes, a joint venture is a business enterprise that is jointly controlled by two or more persons or Entities. [...]
<< Go back to overview Next article>> Article 6.3. Transfer of Assets and Liabilities Article 6.3 provides rules for the recognition or non-recognition of gain or loss on the disposition of assets and liabilities and for determining the carrying values of assets and liabilities acquired in an ordinary acquisition [...]
<< Go back to overview Next article>> Article 6.2. Constituent Entities joining and leaving an MNE Group The GloBE Rules and Commentary are generally drafted on a steady-state basis that assume the MNE Group is comprised of the same Constituent Entities throughout the entire Fiscal Year. When an acquisition [...]
Article 6.1. Application of Consolidated Revenue Threshold to Group Mergers and Demergers As set out in Article 1.1, the GloBE Rules apply to MNE Groups with consolidated revenue of EUR 750 million or more in at least two of the four Fiscal Years immediately preceding the tested Fiscal Year. Article 6.1 complements this [...]
<< Go back to overview Next article>> Article 5.6. Minority-Owned Constituent Entities Special rules are included in Article 5.6 for computing the ETR and Top-up Tax of Minority-Owned Constituent Entities. A Minority-Owned Constituent Entity is a Constituent Entity of the MNE Group where the UPE holds directly or indirectly [...]
Article 5.5. De minimis exclusion Article 5.5 provides a jurisdictional exclusion for LTCEs of an MNE Group when both (i) the aggregated income and (ii) the revenue of those entities do not exceed agreed monetary thresholds. Article 5.5.1 sets out the effects of the exclusion as well as the required conditions to benefit [...]
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