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, 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