<< Go back to overview Next article>> Article 3.4 Allocation of Income or Loss between a Main Entity and a Permanent Establishment A PE is a tax rather than an accounting concept. This means that financial accounting information may not always be separately maintained in respect of the PE. [...]
<< Go back to overview Next article>> Article 3.3 International Shipping Exclusion Article 3.3 provides an exclusion for income derived from international shipping. The international shipping industry has long been subject to industry-specific tax rules. The capital intensive nature, the level of profitability and long economic life cycle of [...]
Article 3.2 - Adjustments to determine GloBE Income or Loss Once the Financial Accounting Net Income or Loss of a Constituent Entity is determined, it is adjusted for certain book to tax differences (that is, differences between financial accounting results and taxable income results) that are common in Inclusive Framework jurisdictions. Differences between [...]
Article 3.1 Financial Accounts The GloBE Rules sets out the computation of GloBE Income or Loss for each Constituent Entity. The starting point for this computation is the Financial Accounting Net Income or Loss of the Constituent Entity calculated in accordance with the rules of Article 3.1. 3.1.1. The GloBE Income or [...]
<< Go back to overview Next article>> Article 2.6 Allocation of Top-Up Tax for the UTPR Articles 2.6.1 to 2.6.3 describe the formula used to allocate the Total UTPR Top-up Tax Amount to each UTPR Jurisdiction on the basis of a substance-based allocation key. 2.6.1.Subject to Articles 2.6.2 [...]
<< Go back to overview Next article>> Article 2.5 UTPR Top-up Tax Amount Article 2.5 provides the methodology to determine the amount of Top-up Tax that is allocated to the UTPR Jurisdiction under the UTPR. The Total UTPR Top-up Tax Amount is determined by reference to the total amount [...]
<< Go back to overview Next article>> Article 2.4 Application of the UTPR The UTPR provides a mechanism for making an adjustment in respect of the Top-up Tax that is calculated for an LTCE to the extent that such Top-up Tax is not brought within the charge of a [...]
<< Go back to overview Next article>> Article 2.3 IIR Offset Mechanism Article 2.3. IIR Offset Mechanism 2.3.1 A Parent Entity that owns an Ownership Interest in a Low-Taxed Constituent Entity indirectly through an Intermediate Parent Entity or a Partially-Owned Parent Entity that is not eligible for an exclusion [...]
<< Go back to overview Next article>> Article 2.2 Allocation of Top-Up Tax under the IIR Entities subject to the IIR pay tax in an amount equal to their “Allocable Share” of Top-up Tax. Article 2.2 contains the rules for the attribution of Top-up Tax under this rule. Article [...]
Article 2.1 Application of the IIR Article 2.1 identifies the Entities in the MNE Group that are required to apply the rule. The IIR is applied by a Parent Entity, which under the definition in Article 10.1, can be a UPE that is not an Excluded Entity, or an Intermediate Parent Entity, or [...]
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