<< Go back to overview Next article>> Article 9.3. Exclusion from the UTPR of MNE Groups in the initial phase of their international activity Article 9.3 provides a transitional exclusion from the UTPR for MNE Groups that are in the initial phase of their international activity. Article 9.3.1 reduces [...]
<< Go back to overview Next article>> Article 9.2. Transitional relief for the Substance-based Income Exclusion 9.2.1. For the purposes of applying Article 5.3.3, the value of 5% shall be replaced with the value set out in the table set out below for each Fiscal Year beginning in each [...]
Article 9.1. Tax Attributes Upon Transition Where an MNE Group has revenues in excess of the revenue threshold, it will become subject to the GloBE Rules after such rules are introduced into the domestic law of a jurisdiction in which the MNE Group operates. Smaller MNE Groups, however, will become subject to the [...]
<< Go back to overview Next article>> Article 8.3. Administrative Guidance Article 8.3.1 contemplates that further guidance on the interpretation or application of the GloBE Rules may be agreed and published by the Inclusive Framework. This Article ensures that when such guidance is issued, it is applied in a [...]
Article 8.2. Safe Harbours It is likely that MNE Groups and tax administrations will incur incremental compliance and administration costs in respect of the application of the GloBE Rules. MNE Groups need to collect, adjust and aggregate information on a jurisdictional basis in order to identify and allocate Top-up Tax in respect of [...]
<< Go back to overview Next article>> Article 8.1. Filing obligation Article 8.1 sets out the requirements for the filing of a GloBE Information Return. The GloBE Information Return is a return in a standardised template form that provides a tax administration with the information it needs to evaluate [...]
<< Go back to overview Next article>> Article 7.6. Taxable Distribution Method Election Article 7.6 provides another alternative to the rule in Article 7.4. This alternative is the Taxable Distribution Method. This method reduces the exposure to Top-up Tax to the extent that the Investment Entity makes distributions of [...]
Article 7.5. Investment Entity Tax Transparency Election 7.5.1. A Filing Constituent Entity may elect to treat a Constituent Entity that is an Investment Entity or an Insurance Investment Entity as a Tax Transparent Entity if the Constituent Entity-owner is subject to tax in its location under a mark-to-market or similar regime based on [...]
Article 7.4. Effective Tax Rate Computation for Investment Entities Investment Entities that are the UPE are excluded from the operation of the GloBE Rules because they are not Constituent Entities of any MNE Group. See Article 1.5.1(e). However, the income of a controlled Investment Entity is consolidated with the MNE Group and brought [...]
<< 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 [...]
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