GloBE Rules

GloBE Rules, IP, OECD, Tax Incentives

(Nishimura & Asahi (Tokyo))/ /Leave a comment

One strategic response of countries to the Global Minimum Tax (the GloBE rules) would be restructuring their tax incentives. The top-up tax effectively nullifies any tax incentive that brings the effective tax rate below 15%. This would push countries to redesign tax incentives that would otherwise produce an effective tax rate below 15%. In a…

GloBE, GloBE Rules, Oil and Gas, Pillar II

(Senior petroleum legal analyst, S&P Global)/ /Leave a comment

Introduction In Fall 2021, almost 140 members of the Organisation for Economic Cooperation and Development (OECD) / Group of Twenty (G20) Inclusive Framework (IF) on Base Erosion and Profit Shifting (BEPS) — a framework for tackling tax planning strategies — agreed on a two-pillar solution, Pillar One and Pillar Two, to address the challenges arising…