Key considerations in OECD Pillar Two global minimum tax model rules

5 May 2022

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Thank you for joining us for a webinar on the latest developments in the global minimum tax rules under Pillar Two of the OECD/G20 BEPS 2.0 Project. Panelists discussed the key elements of the Model Rules, highlighting topics in view of the most recent OECD releases which are particularly relevant to multinational companies and other stakeholders.

Our international tax team covered the following:

• Key mechanics of the GloBE rules and their interplay with GILTI and CFC rules
• Impact of the top-up tax results, such as the qualified domestic minimum top-up tax, permanent and temporary differences, tax attributes of the pre-regime losses and refundable and non-refundable tax credits
• Interplay of the OECD’s Inclusive Framework and US tax reform as well as the European Commission’s proposal for a Pillar Two Directive

For more information

Please contact Sarah Stephens with questions.

In case you missed, visit Global Tax Reform for commentary on recent developments.