https://www.taxtmi.com/article/detailed?id=11841 Location of Constituent Entities and PEs determines jurisdictions for jurisdictional blending of GloBE Income or Loss and allocation of top-up tax. Non-flow-through Entities use tax residence (place of management, place of creation); where none, place of incorporation applies. Flow-through Entities that are the UPE or required to apply an IIR locate where created; other transparent entities are stateless and assessed standalone. PEs locate by treaty, domestic law, or physical location, with limited stateless PE situations. Tie-breaker Rules resolve dual-location by treaty deemed-residence, most Covered Taxes paid (excluding CFC taxes), greater substance via Substance-based Income Exclusion, or statelessness with a UPE exception. en-us Tue, 12 Sep 2023 10:06:52 +0530 Tue, 12 Sep 2023 10:06:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=11841 Location of Constituent Entities and PEs determines jurisdictions for jurisdictional blending of GloBE Income or Loss and allocation of top-up tax. Non-flow-through Entities use tax residence (place of management, place of creation); where none, place of incorporation applies. Flow-through Entities that are the UPE or required to apply an IIR locate where created; other transparent entities are stateless and assessed standalone. PEs locate by treaty, domestic law, or physical location, with limited stateless PE situations. Tie-breaker Rules resolve dual-location by treaty deemed-residence, most Covered Taxes paid (excluding CFC taxes), greater substance via Substance-based Income Exclusion, or statelessness with a UPE exception. Articles Other Topics Tue, 12 Sep 2023 10:06:52 +0530 https://www.taxtmi.com/article/detailed?id=11841