During this webinar, we will present our understanding of the operative provisions of the Pillar Two GloBE Rules including a deep dive into the Top-Up Tax calculations, and show how the GloBE tax calculations use (deferred) tax accounting as a basis. Key learnings are:
What you will learn from this webinar:
- gain a general understanding of the workings of the GloBE Rules
- create awareness how tax accounting is the fundament for Pillar Two / GloBE compliance
- how to prepare for Pillar Two
After this webinar you will have a better understanding of the GloBE operative provisions, the top-up tax calculations and the importance of tax accounting.
Date & Time:
Date: Thursday, April 14th
Time: 03:00 PM (CET)
Duration: approx. 45 minutes (including Q&A)
Hank Moonen, CEO/Founder TaxModel
Rajesh Balgobind, Guest speaker
Unfortunately, due to some technical issues, some of the questions in the Q&A were not visible to our presenters. You can find the answers to all the remaining questions below. Please feel free to share your questions via mail or book a meeting here.
Q: What is the likelihood you think that the implementation will be postponed to 2024/2025? Do you expect that the May Ecofin meeting will formalize the extension of 1 year?
A: Yes, the EU Finance Ministers have expressed broad support for the compromise text for the Pillar Two Directive, which includes a one-year delay of the implementation timeline.
Q: Do you happen to know when the STTR and SOR rules are coming out?
A: There are no statements on this, but for the EU, we expect that these will tag along with the IIR implementation timeline, i.e., 31 December 2023.
Q: Do you think the software you are trying to cover can capture different complexities? Even in Chap 3, the excel file you guys shared earlier reflects only some items, and there are endless permutations and combinations of possibilities.
A: Yes, we believe that Pillar Two will work in the same mechanical way as tax accounting. There are also endless combinations possible for tax accounting, and we have been able to build a solution for this. We always say, if it can be built into a spreadsheet, we can automate it and … much better and much more flexible.
Q: The calculations you displayed – to be done at each group’s legal entity level?
A: Yes, and also for permanent establishments. Please note that for certain entities / PEs, there may be simplified calculations/compliance available due to materiality thresholds and elections.
Q: Good afternoon. In case the mother co has a tax burden under 15%, should the main entity (mother co) also pay top-up tax in their hometown?
A: No, the top-up tax calculated for the mother co would be allocated to and payable by the substance countries that have implemented the UTPR.
Q: The UK implementation is proposed to be on 1 April 2023 (ahead of the EU). Do you expect the UK to delay its implementation to align with the EU timetable?
A: The UK is ahead of most OECD territories and already issued a consultation document on 22 January 2022 (intake of views closed on 4 April 2022). Pillar Two is a long-standing priority for the UK, so it may well be that they keep their own timetable.
On May 12th, we will host our second Pillar Two webinar about the top-up tax allocation under IIR and UTPR. Click here to sign up.