No Match Found
The MR provide helpful guidance on a variety of previously open technical aspects of the GloBE rules. Companies should analyze these new rules but also be cognizant of the fact that this will not be the end of the “story”. MNEs will need to closely follow further discussions/developments to continuously refine their approach towards BEPS 2.0 implementation and maintenance over the next months and years.
Given the quite ambitious time plan for implementation as outlined above, companies should start looking into addressing the incoming operational challenges (e.g. data collection, segmentation, tax accounting determinations and decisions, ERP system readiness) sooner rather than later. Specific attention points in this regard can ideally be properly identified in the coming months and then addressed throughout 2022. This will then also allow for audit readiness when it comes to the tax positions including GloBE in (early) 2023 and it will ensure a good basis for the development of a proper long-term strategy for a target approach to ongoing maintenance of BEPS 2.0 obligations and compliance.
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