OECD publishes Global Anti-Base Erosion Model Rules (Pillar 2)
On December 20, 2021 the OECD published the Global Anti-Base Erosion (‘GloBE’) Model Rules, also known as Pillar 2. The GloBE Rules aim to impose a global minimum tax of 15% on multinational enterprises with a revenue in excess of EUR 750 million.
European Commission’s response to the OECD Pillar 2 model rules
On December 22, 2021, the European Commission published a proposed EU directive to incorporate Pillar Two into EU law. The rules generally mirror the OECD model rules released on December 20, 2021 but have a broader scope that includes large-scale purely domestic groups.
Year end 2021 tax accounting considerations
As the end of the year is fast approaching, many organizations will soon start preparing their year end financial statements. The announced 2022 Tax Plan may have a significant impact on those financials and especially the income tax position. The impact should be reflected once the 2022 Tax Plan is (substantively) enacted.
2022 Tax Plan package amended again via Memorandums of Amendment
The proposals include raising the top corporate income tax rate to 25.8% and tightening the generic interest deduction limitation by reducing the deduction percentage from 30% to 20% of the EBITDA for tax purposes.