As the world of international taxation enters a new era with Pillar Two, we are at the frontiers of change.
The Singapore Ministry of Finance's draft legislation for the Multinational Top-up Tax (MTT) and Domestic Top-up Tax (DTT), the Organisation for Economic Co-operation and Development’s (OECD) latest Administrative Guidance (AG) on the Global Anti-Base Erosion Model Rules (GloBE Rules), Belgium's pioneering registration requirement for in-scope Multinational Enterprise (MNE) Groups, and the Subject-To-Tax-Rule (STTR) Multilateral Instrument signing ceremony all mark significant milestones in this journey.
Join KPMG in an engaging in-person session as they explore the intricacies of these developments and share insights from the successes and challenges faced by MNE Groups across various sectors with practical insights that can help you in your implementation process.
A Highlight of Key Areas:Singapore Draft MTT and DTT Legislation
- Key observations
- Implications of MTT/DTT on Singapore Income Tax Act
OECD’s fourth AG for GloBE Rules
- Guidance on implementation
- Application of recapture rule applicable to Deferred Tax Liabilities
- Divergence between GloBE and accounting carrying values
- Allocation of profits and taxes in structures with flow-through entities
Belgium Pillar Two Registration
- Datapoints expected to be provided by in-scope MNE groups for future Pillar Two registrations
- Best practices to gather data
Treaty-based STTR
- Recap on practical challenges and compliance burden for all tax residents (not just in-scope MNE groups)
Transitional Country-by-Country Reporting Safe Harbour (TCSH)
- FAQs on application
- Application of TCSH for FY 2024 Tax Provisioning (interim reporting and full year reporting)