https://www.taxtmi.com/article/detailed?id=11762 The note urges early impact assessments of the GloBE Pillar Two rules to identify at-risk jurisdictions and estimate potential top-up tax liabilities, explaining the methodology: review group entities and permanent establishments (including excluded, investment, minority-owned and tax-transparent entities), compute GloBE income after Chapter 3 accounting adjustments, allocate adjusted income to entities/PEs, determine Adjusted Covered Taxes (including current and deferred tax adjustments and allocation of withholding taxes), recast deferred tax where accounting tax rates exceed the Pillar Two rate, apply de minimis and substance-based exclusions, and use the GloBE Model Rules and Commentary to estimate any residual top-up tax. en-us Tue, 22 Aug 2023 10:48:23 +0530 Tue, 22 Aug 2023 10:48:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=11762 The note urges early impact assessments of the GloBE Pillar Two rules to identify at-risk jurisdictions and estimate potential top-up tax liabilities, explaining the methodology: review group entities and permanent establishments (including excluded, investment, minority-owned and tax-transparent entities), compute GloBE income after Chapter 3 accounting adjustments, allocate adjusted income to entities/PEs, determine Adjusted Covered Taxes (including current and deferred tax adjustments and allocation of withholding taxes), recast deferred tax where accounting tax rates exceed the Pillar Two rate, apply de minimis and substance-based exclusions, and use the GloBE Model Rules and Commentary to estimate any residual top-up tax. Articles Other Topics Tue, 22 Aug 2023 10:48:23 +0530 https://www.taxtmi.com/article/detailed?id=11762