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Taxes paid by the group

In: Pillar Two of the Inclusive Framework on BEPS

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  • Pitambar Das

Abstract

This chapter examines the GloBE Rules that govern taxes paid by the group. Determination of taxes paid by a CE in a jurisdiction is one of the significant factors for computation of ETR (Effective Tax Rate), which in turn decides the amount of Top-up Tax. However, not all taxes paid by the CE are considered for calculation of ETR. As a general rule, taxes that are associated with GloBE Income or Loss of the CE as computed per Chapter 3 of the Model Rules are relevant for this purpose. As a result, all indirect taxes, excise taxes, payroll taxes, property taxes and the like are excluded from the definition of taxes paid under GloBE Rules because they are not measures of income.

Suggested Citation

  • Pitambar Das, 2024. "Taxes paid by the group," Chapters, in: Carlo Garbarino (ed.), Pillar Two of the Inclusive Framework on BEPS, chapter 3, pages 125-165, Edward Elgar Publishing.
    • Handle: RePEc:elg:eechap:22338_3
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    File URL: https://www.elgaronline.com/doi/10.4337/9781035312382.00012
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    Keywords

    Law - Academic; Law - Professional;

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