GloBE

GloBE, Pillar II, UTPR

(Squire Patton Boggs)/ /1 Comment

By Jefferson VanderWolk Partner, Squire Patton Boggs[1] The GloBE Model Rules were issued in final form in December 2021.  No public consultation was undertaken regarding any draft Model Rules, as there was a need for speed in light of the tight timeline for implementation of Pillar Two’s 15% global minimum tax that had been agreed…

GloBE, IIR, Pillar II

(PhD by the Vienna University of Economics and Business and Tax Associate in Sao Paulo) and (Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados)/ /Leave a comment

1. The IIR and the top-down approach It has become commonplace that the current OECD and Inclusive Framework (IF) proposals to address the tax challenges of the digital economy will represent a fundamental overhaul of the international tax system as we know it. As time passes, the international community has time to digest these possible…