Differences in national accounting standards can make it difficult for users of financial statements,including investors,to correctly assess financial results in each country or compare the business performance from o...Differences in national accounting standards can make it difficult for users of financial statements,including investors,to correctly assess financial results in each country or compare the business performance from one country to another.BRI jurisdictions need to ensure that potential investors have as much information as possible and can make accurate assessments.The best course may be to move to-wards adopting the international accounting standards.The adoption of internation-al standards is considered by the International Accounting Standards Board(IASB)to be a low-cost option for developing countries if they do not have the administrative capacity to develop their own domestic accounting standards.Accounting standards cover the treatment of taxation items,including deferred taxation,in the financial statements.The international accounting standard dealing with income tax is Inter-national Accounting Standards(IAS)12.Using this standard can lead to enhanced tax disclosure,transparency and comparability.In view of the potential impact of the global minimum tax developed under Pillar Two of the OECD proposals,the IASB intends to amend IAS 12 to ensure that tax disclosures in the financial statements re-main comparable.The IASB has proposed a temporary exception to IAS 12 in relation to recognition of deferred tax assets and liabilities relating to Pillar Two taxes.Under the IASB proposals an entity would however be required to disclose information for the current period on Pillar Two legislation enacted in the jurisdictions where it oper-ates.For periods after the global minimum tax comes into effect,an entity would be required to separately disclose the liability to Pillar Two taxes.展开更多
The United States has not yet enacted,or even considered,any legislation designed to implement either of the two pillars in the OECD/G20's two-pillar global tax plan.This article discusses the reasons for this ina...The United States has not yet enacted,or even considered,any legislation designed to implement either of the two pillars in the OECD/G20's two-pillar global tax plan.This article discusses the reasons for this inaction and the prospects for any action by the United States in the future.After reviewing the events that have brought us to the current state of affairs,the discussion considers the Biden Administration's proposals regarding Pillar One and Pillar Two,both internationally(i.e.,in negotiations with other members of the Inclusive Framework)and domestically(i.e.,in the US political and legislative process).The article concludes that it should not be surprising that the US is going its own way in the multilateral tax process.展开更多
This paper explores the compatibility of the Income Inclusion Rule(IIR)and the Undertaxed Profits Rule(UTPR)with existing tax treaties.The paper first assesses whether the taxes under IIR and UTPR meet the coverage cr...This paper explores the compatibility of the Income Inclusion Rule(IIR)and the Undertaxed Profits Rule(UTPR)with existing tax treaties.The paper first assesses whether the taxes under IIR and UTPR meet the coverage criteria of Art.2 of the OECD Model Convention(MC)and then analyses potential treaty infringements,focusing on Art.7,9,and 10(5),highlighting the inherent contradiction between tax treaties,which aim to limit taxing rights,and the global minimum tax,which allows taxation of global profits.Next,the paper reviews the historical development of IIR and UTPR,emphasising the OECD's initial recognition of the need for treaty amendments but noting the current lack of multilateral solutions,which poses potential dispute risks.In conclusion,the paper argues that the global minimum tax presents compliance challenges and legal uncertainties,questioning the binding effect of double taxation agreements.The article calls on the OECD to resolve these uncertainties through international agreements and advises countries to carefully consider the legal implications when implementing the IIR and the UTPR.展开更多
文摘Differences in national accounting standards can make it difficult for users of financial statements,including investors,to correctly assess financial results in each country or compare the business performance from one country to another.BRI jurisdictions need to ensure that potential investors have as much information as possible and can make accurate assessments.The best course may be to move to-wards adopting the international accounting standards.The adoption of internation-al standards is considered by the International Accounting Standards Board(IASB)to be a low-cost option for developing countries if they do not have the administrative capacity to develop their own domestic accounting standards.Accounting standards cover the treatment of taxation items,including deferred taxation,in the financial statements.The international accounting standard dealing with income tax is Inter-national Accounting Standards(IAS)12.Using this standard can lead to enhanced tax disclosure,transparency and comparability.In view of the potential impact of the global minimum tax developed under Pillar Two of the OECD proposals,the IASB intends to amend IAS 12 to ensure that tax disclosures in the financial statements re-main comparable.The IASB has proposed a temporary exception to IAS 12 in relation to recognition of deferred tax assets and liabilities relating to Pillar Two taxes.Under the IASB proposals an entity would however be required to disclose information for the current period on Pillar Two legislation enacted in the jurisdictions where it oper-ates.For periods after the global minimum tax comes into effect,an entity would be required to separately disclose the liability to Pillar Two taxes.
文摘The United States has not yet enacted,or even considered,any legislation designed to implement either of the two pillars in the OECD/G20's two-pillar global tax plan.This article discusses the reasons for this inaction and the prospects for any action by the United States in the future.After reviewing the events that have brought us to the current state of affairs,the discussion considers the Biden Administration's proposals regarding Pillar One and Pillar Two,both internationally(i.e.,in negotiations with other members of the Inclusive Framework)and domestically(i.e.,in the US political and legislative process).The article concludes that it should not be surprising that the US is going its own way in the multilateral tax process.
文摘This paper explores the compatibility of the Income Inclusion Rule(IIR)and the Undertaxed Profits Rule(UTPR)with existing tax treaties.The paper first assesses whether the taxes under IIR and UTPR meet the coverage criteria of Art.2 of the OECD Model Convention(MC)and then analyses potential treaty infringements,focusing on Art.7,9,and 10(5),highlighting the inherent contradiction between tax treaties,which aim to limit taxing rights,and the global minimum tax,which allows taxation of global profits.Next,the paper reviews the historical development of IIR and UTPR,emphasising the OECD's initial recognition of the need for treaty amendments but noting the current lack of multilateral solutions,which poses potential dispute risks.In conclusion,the paper argues that the global minimum tax presents compliance challenges and legal uncertainties,questioning the binding effect of double taxation agreements.The article calls on the OECD to resolve these uncertainties through international agreements and advises countries to carefully consider the legal implications when implementing the IIR and the UTPR.
