Global Minimum Tax Series
(Part 23) Dated – 22.09.2023
CA Amit Jalan
In This Edition :
In the previous two editions, viz. 21 and 22, we have discussed as identify the location of the Constituent Entities based on which the GloBE Income or Loss and Covered Tax calculation and allocation mechanisms are designed as well as the India has agreed to this global pact to ensure that in-scope large corporations pay a 15% Global Minimum Tax and how would MNEs with operations / entities in India could be impacted with this.
Global Minimum Tax Series
(Part 22) Dated – 08.09.2023
CA Amit Jalan
In This Edition :
In the previous two editions, viz. 20 and 21, we have discussed the MNE Group is within the scope of the GloBE Rules upon the in-scope test being met, the identification of entities that are Constituent Entities and those that are Excluded Entities is a key aspect to determine as well as identify the location of the Constituent Entities based on which the GloBE Income or Loss and Covered Tax calculation and allocation mechanisms are designed.
Global Minimum Tax Series
(Part 21) Dated – 25.08.2023
CA Amit Jalan
In This Edition :
In the previous two editions, viz. 19 and 20, we have discussed detail another important aspect, viz. Stateless Entities as well as the MNE Group is within the scope of the GloBE Rules upon the in-scope test being met, the identification of entities that are Constituent Entities and those that are Excluded Entities is a key aspect to determine.
Global Minimum Tax – Part 20
(Part 20) | Dated: 18.08.2023
CA Amit Jalan
In This Edition :
Constituent Entities and Excluded Entities
In the previous two editions, viz. 18 and 19, we have discussed the OECD realising this has formulated special rules within the GloBE Rules relating to allocation of GloBE Income or Loss and Covered Tax for such entities as well as detail another important aspect, viz. Stateless Entities.
Global Minimum Tax – Part 19
(Part 19) | Dated: 28.07.2023
CA Amit Jalan
In This Edition :
Stateless Entities under GloBE Rules
In the previous two editions, viz. 17 and 18, we have discussed the rules around a key aspect of the GloBE Rules, viz. Permanent Establishments as well as the GloBE Rules relating to allocation of GloBE Income or Loss and Covered Tax for such entities.
Global Minimum Tax – Part 18
(Part 18) | Dated: 21.07.2023
CA Amit Jalan
In This Edition :
Treatment of Flow-through Entities
In the previous two editions, viz. 16 and 17, we have discussed one key aspect talked about within the GloBE Rules, i.e., Permanent Establishments and all the rules around it as contained within the Model Rules as well as the rules around a key aspect of the GloBE Rules, viz. Permanent Establishments
Global Minimum Tax Series
(Part 17) | Dated: 14.07.2023
CA Amit Jalan
In This Edition :
Flow Through and Tax Transparent Entities
In the previous two editions, viz. 15 and 16, we have discussed the GloBE Rules, i.e., Permanent Establishments and all the rules around it as contained within the Model Rules as well as one key aspect talked about within the GloBE Rules, i.e., Permanent Establishments and all the rules around it as contained within the Model Rules..
Global Minimum Tax : 16 – Permanent Establishments under GloBE
Edn. 16
CA Amit Jalan
In This Edition :
Permanent Establishments under GloBE
In the previous two editions, viz. 14 and 15, we have discussed One primary concept based on which the GloBE Rules have been designed is the Jurisdictional Blending approach as well as the GloBE Rules, i.e., Permanent Establishments and all the rules around it as contained within the Model Rules.
GLOBAL MINIMUM TAX SERIES: 15 – Need for GloBE Pillar 2 Impact Assessment
Edn. 15
CA Amit Jalan
In This Edition :
Need for GloBE Pillar 2 Impact Assessment
In the previous two editions, viz. 13 and 14, we have discussed special rules under the Pillar Two that apply to Minority Owned Constituent Entities as well as One primary concept based on which the GloBE Rules have been designed is the Jurisdictional Blending approach.
GLOBAL MINIMUM TAX SERIES: 14
Edn. 14
CA Amit Jalan
In This Edition :
Jurisdictional Blending for GloBE Rules
In the previous two editions, viz. 12 and 13 we have discussed in detail the provisions of the De Minimis exclusion rule as contained within article 5.5 of the GloBE Rules as well as special rules under the Pillar Two that apply to Minority Owned Constituent Entities.
GLOBAL MINIMUM TAX SERIES: 13 – GloBE Rules for Minority Owned Entities
Edn. 13
CA Amit Jalan
In this edition:
In the previous two editions, viz. 11 and 12 we have discussed that two temporary and one permanent safe harbours that have been currently released by the OECD as well as in detail the provisions of the De Minimis exclusion rule as contained within article 5.5 of the GloBE Rules.
GLOBAL MINIMUM TAX SERIES: 12 – GloBE De Minimis Exlusion Rule
Edn. 12
CA Amit Jalan
In this edition:
The provisions of the De Minimis exclusion rule as contained within Article 5.5 of the GloBE Rules.
GLOBAL MINIMUM TAX SERIES: 11 – Pillar Two Safe Harbours
Edn. 11
CA Amit Jalan
In this edition:
The safe harbours and penalty reliefs for the Pillar Two GloBE rules as issued by the OECD.
GLOBAL MINIMUM TAX SERIES: 10 – GloBE Safe Harbour Rule
Edn. 10
CA Amit Jalan
In this edition:
Key provisions within the GloBE Rules on Safe Harbour.
GLOBAL MINIMUM TAX SERIES: 9 – Rules on Corporate Restructurings and Holding Structures – Multi-Parented MNE Group
Edn. 09
CA Amit Jalan
In this edition:
Topics on corporate restructurings determining the application of GloBE Rules to MNE Groups particularly in case of mergers, demergers, acquisitions, joint ventures, etc. This edition is the last one in that series where we are discussing on special rules for Multi-Parented MNE Groups.
GLOBAL MINIMUM TAX SERIES: 8 – Rules on Corporate Restructurings & Holding Structures – Joint Ventures
Edn. 08
CA Amit Jalan
In this edition:
Detail on special rules that deal with corporate restructurings (including mergers, acquisitions, and demergers) and covered in detail Article 6.3 relating to the rules for treatment of transfers of assets and liabilities including as part of a reorganisation.
GLOBAL MINIMUM TAX SERIES: 7 – Rules on Corporate Restructurings and Holding Structures
Edn. 07
CA Amit Jalan
In this edition:
Detail on special rules that deal with corporate restructurings (including mergers, acquisitions, and demergers) and covered in detail Article 6.2 relating to the rules that apply when a Constituent Entity enters or leaves an MNE Group during the Fiscal Year.
GLOBAL MINIMUM TAX SERIES: 6 – Rules on Corporate Restructurings and Holding Structures
Edn. 06
CA Amit Jalan
In this edition:
Special rules that deal with corporate restructurings (including mergers, acquisitions, and demergers) and covered in detail Article 6.1 relating to application of Consolidated Revenue Threshold to Group Mergers and Demergers.
6 – Rules on Corporate Restructurings and Holding Structures
GLOBAL MINIMUM TAX SERIES – Rules on Corporate Restructurings and Holding Structures
Edn. 05
CA Amit Jalan
In this edition:
Special rules that deal with corporate restructurings (including mergers, acquisitions, and demergers) as well as Articles that address the application of the GloBE Rules to certain holding structures such as JV investments and Multi-Parented MNE Groups.
5-Rules on Corporate Restructurings and Holding Structures 20230421
GLOBAL MINIMUM TAX SERIES – Guidance on Deemed Consolidation test in the GloBE Rules
Edn. 04
CA Amit Jalan
In this edition:
The guidance issued in relation to the deemed consolidation test under GloBE Rules requires the preparation of a set of Consolidated Financial Statements based on an Authorized Financial Accounting Standard in the Ultimate Parent Entity’s (“UPE”) location………………
GLOBAL MINIMUM TAX SERIES – Guidance on Rebasing monetary thresholds in the Globe Rules
Edn. 03
CA Amit Jalan
In this edition:
1. The GloBE Rules contain several monetary thresholds expressed in Euros (EUR)
2. To ensure consistency in the monetary thresholds used by different jurisdictions including those that are expressed in non-EUR currency, the Administrative Guidance provides for an annual rebasing of the non-EUR denominated thresholds based on:
3. The Administrative Guidance also provides that the foreign exchange rate for each individual year for the purposes of determining the relevant threshold translated into local currency will be based on the average foreign exchange rate for December of the calendar year immediately preceding the calendar year in which such Fiscal Year starts and not a single foreign exchange rate applied for the purposes of all the relevant Fiscal Years.