Wildy Logo
(020) 7242 5778
enquiries@wildy.com

Book of the Month

Cover of Borderlines in Private Law

Borderlines in Private Law

Edited by: William Day, Julius Grower
Price: £90.00

Lord Denning: Life, Law and Legacy



  


Welcome to Wildys

Watch


NEW EDITION
The Law of Rights of Light 2nd ed



 Jonathan Karas


Offers for Newly Called Barristers & Students

Special Discounts for Newly Called & Students

Read More ...


Secondhand & Out of Print

Browse Secondhand Online

Read More...


Annotations on the OECD Global Anti-Base Erosion Model Rules (Pillar 2) (eBook)

Edited by: Stefano Grilli, Dennis Weber

ISBN13: 9789403544069
Published: September 2024
Publisher: Kluwer Law International
Country of Publication: Netherlands
Format: eBook (ePub)
Price: £170.00
The amount of VAT charged may change depending on your location of use.


The sale of some eBooks are restricted to certain countries. To alert you to such restrictions, please select the country of the billing address of your credit or debit card you wish to use for payment.

Billing Country:


Sale prohibited in
Korea, [North] Democratic Peoples Republic Of

Due to publisher restrictions, international orders for ebooks may need to be confirmed by our staff during shop opening hours. Our trading hours are Monday to Friday, 8.30am to 5.00pm, London, UK time.


The device(s) you use to access the eBook content must be authorized with an Adobe ID before you download the product otherwise it will fail to register correctly.

For further information see https://www.wildy.com/ebook-formats


Once the order is confirmed an automated e-mail will be sent to you to allow you to download the eBook.

All eBooks are supplied firm sale and cannot be returned. If you believe there is a fault with your eBook then contact us on ebooks@wildy.com and we will help in resolving the issue. This does not affect your statutory rights.

This eBook is available in the following formats: ePub.

In stock.
Need help with ebook formats?




Also available as

Annotations on the OECD Global Anti-Base Erosion Model Rules (Pillar 2) is a first-of-its-kind book that provides an in-depth survey of the implications of Pillar 2 of the OECD Global Anti-Base Erosion Model Rules for all stakeholders, with detailed annotations by nineteen renowned experts in the field of multinational corporate taxation who describe the relevant provisions with examples and considerations addressing their scope, functioning, and interaction. Although still under development, Pillar 2 Rules already pose significant challenges for taxation authorities globally. Intended to establish a floor in the possibilities for countries to compete for corporate investment with each other in corporate income taxation, the Pillar 2 Rules arising from the OECD/G20 Inclusive Framework have been agreed on by 140 countries.

What’s in this book:

Based on a comprehensive discussion of the Rules, their technical operation, and the administrative guidance provided by OECD, topics covered include the following:

  • definitions of tax terms for Pillar 2 purposes
  • computation of income or loss, adjusted covered taxes, effective tax rate, and top-up tax
  • jurisdictional blending and loss offsets
  • effect of corporate restructurings and holding structures
  • excluded categories of income
  • carve-out opportunities under the Substance-Based Income Exclusion (SBIE)
  • transitional country-by-country and time-limited safe harbours, and
  • differences and interactions between the OECD Global Anti-Base Erosion (GloBE) and both the EU Pillar 2 Directive and the US Global Intangible Low-Taxed Income (GILTI) regimes

How this will help you:

It has been estimated that the GloBE reform would produce a global additional tax revenue of USD 200 billion annually. Thus, taxation authorities, tax practitioners, and multinational corporate counsel must become as aware as possible of the intricacies of the Pillar 2 Rules. For this reason, this detailed discussion and analysis will be greatly appreciated by taxation professionals worldwide.

Subjects:
Taxation, eBooks
Contents:
Preface and Acknowledgements

CHAPTER 1. Scope and Main Definitions
Maarten de Wilde
CHAPTER 2A. Charging Provisions
Marco Adda & Francesco Giuliano Parlatore
CHAPTER 2B. Charging Provisions: UTPR
Paolo Arginelli
CHAPTER 3A. Computation of GloBE Income or Loss
Giuseppe Francesco Patti
CHAPTER 3B. Computation of GloBE Income or Loss: International Shipping Income Exclusion (Article 3.3)
Ton Stevens
CHAPTER 3C. Computation of GloBE Income or Loss: Allocation of Income or Loss Between a Main Entity and a Permanent Establishment, and From a Flow-Through Entity
Kasper Dziurdz & Christoph Marchgraber
CHAPTER 4A. The Computation of Adjusted Covered Taxes
Dieter Bettens
CHAPTER 4B. The Computation of Adjusted Covered Taxes: Mechanism to Address Temporary Differences, the GloBE Loss Election, Post-filling Adjustments and Tax Rate Changes
Ana Paula Dourado & Leidson Rangel
CHAPTER 5. Computation of Effective Tax Rate and Top-Up Tax
Maarten de Wilde
CHAPTER 6. Corporate Restructuring and Holding Structures
Federica Pitrone
CHAPTER 7. Tax Neutrality and Distribution Regimes
Hein Vermeulen
CHAPTER 8A. Administration
Sigrid Hemels
CHAPTER 8B. Transitional CbCR Safe Harbours
Luca Bosco
CHAPTER 9. Transitional Rules
Marco Busia
CHAPTER 10. Differences Between the OECD’s GloBE Model Rules and the EU’s GloBE Directive
Rita Szudoczky & Valentin Bendlinger
CHAPTER 11. Pillar 2 and GILTI: Coexistence, Conformity or Fracture?
Mindy Herzfeld

Index