Antonio Lanotte的动态

On #taxnotesinternational?Tax Analysts: My takeaway on Global Minimum Taxation #GloBE (Pillar 2) with practical examples inside (link to the article in the first comment). Thanks to Jéanne Rauch-Zender and Tax Notes for hosting me. Main points to look at: ??The EU can play a leading role in these efforts e for pillar 2 in relation to the global anti-base-erosion (GLOBE) mechanism. The GLOBE (pillar 2) rules provide for a coordinated system of taxation to ensure that large MNE groups pay a minimum level of tax in each of the jurisdictions in which they operate. ??#Pillar1 targets a #fairerdistribution of #profits and #taxationrights between #countries for the largest #MNEs and #digitalcompanies. It will primarily require MNEs to pay part of their income taxes where their consumers and users are located, creating a link between profits and market jurisdictions. ??#Pillar2 aims to ensure that large #MNEs, especially #digitized MNEs, pay a minimum effective tax rate of 15 percent, establishing a regulatory framework that discourages #profitshifting and prevents #harmfultaxcompetition between jurisdictions. This would effectively remove competitive corporate income tax rates and result in a global minimum rate countries can use to protect their tax bases ??#GLOBE rules impose a top-up tax using an #ETR test calculated on a jurisdictional basis using a common definition of covered taxes, and a tax base determined by reference to financial accounting income (with agreed adjustments consistent with pillar 2 tax policy objectives and mechanisms to address timing differences). ??Finally, the ability of a country to draft and design its #owntaxstrategy independently is fundamental for any so-called #sovereign state. It is not necessary to break with this paradigm to redefine its #boundaries to be #global and centered on #digitaltechnology. Getting there requires a redefinition of national sovereignty to a broader concept: #supranational. ??Fundamental supranational issues and the enormous economic interdependencies generated through the #digitizedeconomy clash with many states that take unilateral paths and have no intention of giving up their fiscal sovereignty. Global Blockchain Business Council (GBBC) Global Digital Finance Blockchain for Europe EU Blockchain Observatory and Forum CFE Tax Advisers Europe