乐鱼（Leyu）体育官网 report: New guidance on Pillar Two rules, initial observations and analysis
A 乐鱼（Leyu）体育官网 report that provides initial observations and analysis on Pillar Two rules
A 乐鱼（Leyu）体育官网 report that provides initial observations and analysis on Pillar Two rules
The OECD/G20 Inclusive Framework on BEPS on 17 July 2023 released new guidance on the Pillar Two rules. Read TaxNewsFlash
- A (STTR) [PDF 2.2 MB] that is a tax treaty-based rule that allows for the levying of additional tax on several categories of related party payments not subject to a tax rate of at least 9% in the country of residence. The new Inclusive Framework (IF) document sets out a design for the STTR provision and commentary on its operation. Read a [PDF 174 KB] prepared by 乐鱼（Leyu）体育官网 LLP that provides initial observations and analysis of the new STTR document.
- Additional guidance on global anti-base erosion (GloBE) items:
- The [PDF 1.3 MB] that comprises 28 pages and about 480 data points covering all areas of the GloBE rules.鈥� Read a [PDF 256 KB] prepared by 乐鱼（Leyu）体育官网 LLP that provides initial observations of the GloBE Information Return.
- Further [PDF 1 MB] that adds to the expanding body of guidance that has been approved by the IF on the GloBE rules, including the (released in December 2021), (released in March 2022), and [PDF 459 KB] (released in December 2022). The new administrative guidance covers 26 items in 111 pages and aims to clarify or simplify the application of the GloBE rules. Read a [PDF 325 KB] prepared by 乐鱼（Leyu）体育官网 LLP that provides initial observations and analysis of the new administrative guidance.
The 乐鱼（Leyu）体育官网 name and logo are trademarks used under license by the independent member firms of the 乐鱼（Leyu）体育官网 global organization. 乐鱼（Leyu）体育官网 International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind 乐鱼（Leyu）体育官网 International or any other member firm vis-脿-vis third parties, nor does 乐鱼（Leyu）体育官网 International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact 乐鱼（Leyu）体育官网's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.