OECD vydala další výklad k Pilíři 2

OECD issued yet another Pillar 2 Administrative Guidance

OECD keep us busy and issued the fourth set of Pillar 2 Administrative Guidance (see HERE).

This package includes guidance on the following areas:

• recapture rule applicable to deferred tax liabilities (DTL), including how to aggregate DTL categories and methodologies for determining whether a DTL reversed within five years;
• clarification on how to determine deferred tax assets and liabilities for GloBE purposes when the rules result in divergences between GloBE and accounting carrying value of assets and liabilities;
• cross-border allocation of current and deferred taxes,
• allocation of profits and taxes in certain structures involving Flow-through Entities,
• the treatment of securitisation vehicles.

This Administrative Guidance should be prospectively incorporated into the OECD Pillar 2 Commentary.

If you have any questions, please contact the authors of this article or the EY tax team with whom you regularly work.

Authors:

Karel Hronek

Tereza Pospíšilová