The Resource Can the switch-over rule and the role of permanent establishments be considered the neglected stepchildren of the GloBE proposal?

Can the switch-over rule and the role of permanent establishments be considered the neglected stepchildren of the GloBE proposal?

Label
Can the switch-over rule and the role of permanent establishments be considered the neglected stepchildren of the GloBE proposal?
Title
Can the switch-over rule and the role of permanent establishments be considered the neglected stepchildren of the GloBE proposal?
Creator
Subject
Language
eng
Summary
This article examines the switch-over rule for GloBE purposes and how (low-taxed) permanent establishments are generally dealt with under the GloBE proposal. Subsequently it describes the application of the GloBE proposal to permanent establishments, considering the subject-to tax rule, the calculation of the effective tax rate, the income inclusion rule, and the switch-over rule. Further, it discusses design issues with regard to the switch-over rule in both its current form and, as to be explored by the Inclusive Framework, on a standalone basis
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 49 (2021), no. 12 ; p. 986-994
http://library.link/vocab/creatorName
Schwarz, M. (Magdalena)
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • GloBE Proposal (OECD)
  • switchover clause
  • PE
  • subject to tax
  • UTPR
  • IIR
  • subject to tax
  • Pillar 2 (OECD)
  • global minimum tax
  • Inclusive Framework (OECD)
Label
Can the switch-over rule and the role of permanent establishments be considered the neglected stepchildren of the GloBE proposal?
Instantiates
Publication
Label
Can the switch-over rule and the role of permanent establishments be considered the neglected stepchildren of the GloBE proposal?
Publication

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