Page 66 - Pillar Two News Today

To print this article, all you need is to be registered or login on Mondaq.com. As discussed in prior blog posts, Amount A is a proposed new taxing right over a share of the residual profit of MNE groups that fall within its defined scope. The tax base is therefore determined on the basis of the profits of a group (rather than on a separate entity basis), and it is necessary to start with consolidated group financial accounts. Comment: As discussed in prior blog posts, t...

UK Case Law Developments The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision (as reported in our November 2019 UK Tax Round Up) and agreed with the FTT that enterprise investment scheme (EIS) relief was not available for a class of shares owing to the mechanics in the company’s articles of association for paying out dividends. This case shows the importance of careful drafting of share rights if EIS relief is inten...

To print this article, all you need is to be registered or login on Mondaq.com. The COVID-19 pandemic has caused such a devastating impact on human life and health, and the global economy. As a consequence, the funds industry has faced unprecedented challenges, as it continues to navigate through unchartered waters. Before the pandemic, many institutional investors and pension funds had increased their allocations to alternative investment funds sector. Due to the extrem...

To print this article, all you need is to be registered or login on Mondaq.com. On 12 October 2020, the OECD released for public consultation updated reports on its two-pillar proposal to address the tax challenges of the digitalisation of the economy. The Pillar One proposal focuses on new nexus and profit allocation rules for certain business models, whereas the Pillar Two proposal pursues more broadly a global minimum effective taxation. The reports identify key issue...

Find international consensus for taxing the digital economy, says ICAEW 15 December: ICAEW’s Tax Faculty has urged the OECD to work with its members to agree an approach to the taxation of multinationals to replace the plethora of digital services taxes being introduced unilaterally across the world. In a response to the OECD’s consultation on its Pillar One and Two proposals, ICAEW’s Tax Faculty has welcomed the delay in finalising the rules until mid-2021 to ...