QDMTT and UTPR Safe Harbours QDMTT Safe Harbour 1. A Qualified Domestic Minimum Top-up Tax (QDMTT) is a domestic minimum tax imposed by a jurisdiction on those Constituent Entities of an MNE Group that are resident, or constitute a permanent establishment in, that jurisdiction. The QDMTT operates as a Top-up Tax that is [...]
Introduction to the GloBE Rules - OECD Commentary 1. The Global Base Erosion rules (GloBE Rules) have been developed as part of the solution for addressing the tax challenges of the digital economy. They are designed to ensure large multinational enterprises (MNEs) pay a minimum level of tax on the income arising in [...]
<< Go back to overview Next article>> Globe Information Return (GIR) The GloBE Information Return (GIR) contains the information a tax administration needs to perform an appropriate risk assessment and to evaluate the correctness of a Constituent Entity (CE)’s Top-up Tax liability. In particular, Article 8.1.4 of the GloBE [...]
<< Go back to overview Next article>> Transitional Penalty Relief The penalty relief described in this Chapter is designed to provide transitional relief for MNE groups in the initial years during which the GloBE Rules come into effect. It reflects a common understanding amongst implementing jurisdictions on the necessity [...]
<< Go back to overview Next article>> Permanent Safe Harbour Where an MNE’s operations in a jurisdiction do not meet the requirements of a transitional safe harbour, they may still qualify for the terms of a permanent safe harbour. Similar to the Transitional CbCR Safe Harbour, qualifying for the [...]
<< Go back to overview Next article>> Transitional CbCR Safe Harbour The safe harbour described in this Chapter is designed to provide transitional relief for MNE Groups in the initial years during which the GloBE Rules come into effect. This safe harbour seeks to ameliorate the immediate compliance difficulties [...]
<< Go back to overview Next article>> Article 10.3. Location of an Entity and a Permanent Establishment Article 10.3 sets out the rules that determine the location of an Entity and a PE for purposes of the GloBE Rules. Determining the location of an Entity and PE is important [...]
Article 10.2. Definitions of Flow-through Entity, Tax Transparent Entity, Reverse Hybrid Entity, and Hybrid Entity Article 10.2 contains the definitions of the terms Flow-through Entity, Tax Transparent Entity, Reverse Hybrid Entity and Hybrid Entity. These terms are used in different parts of the GloBE Rules, in particular, in Article 3.5 that regulates the [...]
Article 10.1. Defined Terms Article 10.1 contains defined terms that are used in the GloBE Rules. The majority of these terms are discussed in the Commentary to the Articles that use those terms. The remaining defined terms are discussed here in the Commentary to Article 10.1. The GloBE Rules and Commentary also use [...]
<< 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 [...]
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