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Mechanism to apply the minimum tax

In: Pillar Two of the Inclusive Framework on BEPS

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  • Giovanni Rolle

Abstract

This chapter sets out the mechanism to apply the minimum tax under the GloBE Rules. It considers parent entities liable to pay Top-Up tax and the allocation of Top-Up tax under the Income Inclusion Rule (IIR) allocation of Top-Up tax under the IIR. It further considers the backstop mechanism contained in the Undertaxed Payments Rule (UTPR) and the allocation of Top-Up tax under the UTPR.

Suggested Citation

  • Giovanni Rolle, 2024. "Mechanism to apply the minimum tax," Chapters, in: Carlo Garbarino (ed.), Pillar Two of the Inclusive Framework on BEPS, chapter 5, pages 194-227, Edward Elgar Publishing.
    • Handle: RePEc:elg:eechap:22338_5
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    File URL: https://www.elgaronline.com/doi/10.4337/9781035312382.00014
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    Keywords

    Law - Academic; Law - Professional;

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