Transitional Rules

<< Go back to overview Next article>> Article 9.4. Transitional relief for filing obligations Article 9.4.1 provides transitional relief for the filing and notification obligations pursuant to Article 8.1 with respect to the Transition Year. The filing and notification obligations must be fulfilled within 18 months, rather than the [...]

<< Go back to overview Next article>> Article 9.3. Exclusion from the UTPR of MNE Groups in the initial phase of their international activity Article 9.3 provides a transitional exclusion from the UTPR for MNE Groups that are in the initial phase of their international activity. Article 9.3.1 reduces [...]

<< Go back to overview Next article>> Article 9.2. Transitional relief for the Substance-based Income Exclusion 9.2.1. For the purposes of applying Article 5.3.3, the value of 5% shall be replaced with the value set out in the table set out below for each Fiscal Year beginning in each [...]

Article 9.1. Tax Attributes Upon Transition Where an MNE Group has revenues in excess of the revenue threshold, it will become subject to the GloBE Rules after such rules are introduced into the domestic law of a jurisdiction in which the MNE Group operates. Smaller MNE Groups, however, will become subject to the [...]