a. Here different outcomes if UPE in jurisdiction with IIR:
-> Top-up tax of LTCEs limited to UPEs Allocable Share of Top-up Tax due in respect of each LTCE.
-> Special treatment for POPEs (= split-ownership structures where LTCEs have more than 20% third party minority interest holders): Lower tier POPE jurisdiction has priority to apply IIR to extent of its Allocable Share (exception to IIR top-down approach).
b. If UPE in jurisdiction without IIR:
-> IIR Top-up tax with Intermediate Parent(s) that partially own LTCEs reduces total Top-up Tax Amount and hence leaves a Top-up Tax delta (including the one attributable to third party minority owners) which then is subject to reallocation among all UTPR countries. Hence total Top-up Tax due in respect of LTCEs can be greater than in scenario a.
A) Additions and reductions to covered taxes and definition of covered taxes;
B) Allocation between CEs;
C) Temporary differences;
D) GloBE Loss election;
E) Post-filing adjustments and tax rate changes.
A) Computational rules for determining the ETR of jurisdictions in which the MNE operates and for determining the Top-up Tax for a Low-Tax Jurisdiction.
B) Rules for determining the amount of income that is excluded from the GloBE Rules by virtue of the Substance-based Income Exclusion.
C) Additional Current Top-up Tax.
D) De Minimis Exclusion.
A) Filing obligation
B) Safe Harbours
C) Administrative Guidance
A) Tax Attributes;
B) the Substance-based Income Exclusion;
C) the exclusion from the UTPR of MNE Groups in the initial phase of their international activity and
D) for Filing Obligations
Partner and Leader Corporate Tax Services, Zurich, PwC Switzerland
+41 58 792 53 10
Partner, Transfer Pricing and Value Chain Transformation, Geneva, PwC Switzerland
+41 58 792 95 60
Director - Transfer Pricing & Value Chain Transformation, Zurich, PwC Switzerland
+41 58 792 44 87
Manager - Transfer Pricing and Value Chain Transformation, Geneva, PwC Switzerland
+41 58 792 96 70
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