Transfer pricing Miscellaneous 2021

OECD's Pillar 2 global minimum tax proposal: Taking the pressure off transfer pricing

Source: National

Published Date: 9 Sep 2021


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This paper covers:

  • The current state of play on the OECD's Pillar 2 program
  • An overview of the Pillar 2 domestic law change proposals (the income inclusion rule and the undertaxed payments rule, together known as the GloBE rules) including identifying which entities are in-scope, the effective tax rate (ETR) calculation and identifying who pays the top-up tax
  • An overview of the Pillar 2 treaty based changes (the switch-over rule and subject to tax rule)
  • An analysis of implementation issues and next steps
  • Consideration of the major impacts of the changes, especially on transfer pricing.


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Transfer pricing Miscellaneous 2021

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