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Replace Calculations in the Tax Agreement

Replace Calculations in the Tax Agreement and eSign it in minutes

Aug 6th, 2022

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Got questions?

Below are some common questions from our customers that may provide you with the answer you're looking for. If you can't find an answer to your question, please don't hesitate to reach out to us.

What is the subject to tax rule?

It is a treaty based rule that specifically targets risks to source jurisdictions posed by BEPS structures relating to intragroup payments which take advantage of low nominal rates of taxation in the other contracting jurisdiction (that is, the jurisdiction of the payee).

What is Article 9 of the MLI?

Article 9(1) of the MLI Capital Gains from Alienation of Shares or Interests of Entities Deriving their Value Principally from Immovable Property provides that contracting jurisdictions shall (i) adopt the 365-day holding period requirement for shares from the alienation of which gains arise, and (ii) expand the

What is amount a in Pillar 1?

Amount A of Pillar One introduces a new taxing right over a portion of the profit of large and highly profitable enterprises for jurisdictions in which goods or services are supplied or consumers are located.

What is the qualified income inclusion rule?

Under the Income Inclusion Rule, top-up tax is paid at the parent entity level based on its proportion of ownership interests in entities with low-taxed income.

What is the computation of income?

The computation of income is the total value of goods and services produced by a country for a financial year. It is the monetary equivalent of the net product of all economic activity in a nation.

How does the global minimum tax work?

In the deepest overhaul of cross-border tax rules in a generation, nearly 140 countries had agreed in 2021 to apply a minimum tax rate of 15% on multinationals by committing to a top-up tax on profits booked in countries that have lower rates.

How is substance-based income exclusion calculated?

A substance-based income exclusion provides that the GloBE Income (taxable base) is reduced by a percentage of payroll costs and the carrying value of tangible assets. The percentage of payroll costs starts at 10% and is gradually reduced each year until 2033 when it will be 5%.

What is the switch over rule?

Switch-over rule (SOR): applies where a permanent establishment is undertaxed, switching off a treaty-based exemption in the head office jurisdiction and replacing it with a credit-based method of taxation.

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