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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 normal 15 months, after the end of the Reporting Fiscal Year that is the Transition Year.

9.4.1. Notwithstanding Article 8.1.6, the GloBE Information Return or the notifications pursuant to Article 8.1 shall be filed with the tax administration of [implementing-Jurisdiction] no later than 18 months after the last day of the Reporting Fiscal Year that is the Transitional Year.

Country Profile – Japan

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Model Rules – QDMTT and UTPR Safe Harbours

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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 [...]

Introduction to the GloBE Rules – OECD Commentary

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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. [...]

Model Rules – Globe Information Return

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<< 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 [...]

Model Rules – Transitional Penalty Relief

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<< 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 [...]

Model Rules – Permanent Safe Harbour

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<< 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 [...]