Model Rules – Article 5.3.
2023-08-12T19:03:47+02:00Article 5.3. Substance-based Income Exclusion The policy rationale behind a formulaic, substance-based carve-out, based on payroll and tangible assets is to exclude a fixed return for substantive activities within a jurisdiction from the application of the GloBE Rules. The use of Payroll and Tangible Assets as indicators of substantive activities is justified because [...]
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