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

Resource Information

The work Can the switch-over rule and the role of permanent establishments be considered the neglected stepchildren of the GloBE proposal? represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

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

Creator

• Schwarz, M. (Magdalena)

Subject

• IIR
• Inclusive Framework (OECD)
• PE
• Pillar 2 (OECD)
• GloBE Proposal (OECD)
• global minimum tax
• subject to tax
• switchover clause
• UTPR

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

Geographic coverage

International

Language note

English