Third Pillar II Roundtable: Constituent Entities & GloBE income/expense

Hi All,

If you are interested in the this Roundtable, in order to receive the webinar invitation, please register via this link: Roundtable 3

Registration for already the third Pillar II virtual Roundtable is open: Constituent Entities & GloBE income/expense on March 26. In this Roundtable we will discuss the Pillar II rules qualifying (Constituent) Entities or Entities as Partially Owned Parent Entity, Intermediate Parent Entity, Joint Venture, partly / wholly owned entity, etc. The consequence of such qualification may have an effect on the calculation of the Globe Income, including ‘blending group/scope’ relevant for determining the amount of Adj. Covered Taxes for a jurisdiction. In this Roundtable, Loyens & Loeff will guide us though this complex set of rules and are available to answer all your questions.

Below this message, you can find a summary of the first 2 Roundtables. Closer to date I will follow-up with a message explaining how you can submit questions in relation to Constituent Entities & GloBE income/expense.

We are looking forward to see you on the 26^th!

Doris Gonzalez-Hurtado │ Mark Tan │ Mathias Knittel │ Juan Carlos Rubio │ Ralf Thelosen

Roundtable 1 on the Project Approach on January 30

In the first Roundtable, we explored with a panel of TEI members how some companies are getting organized to deal with Pillar Two planning and compliance, from the perspectives of:

• a US UPE / US-listed MNC
• a CH UPE / non-listed PE & sovereign wealth fund owned
• an EU cooperative UPE / non-listed MNC

The discussions touched on how each type of company started their Pillar Two projects, how each went about securing internal and external resources, dealt with questions on the source of data and the link to Country by Country Report data, as well as the technology being used or being explored for modelling and future compliance.

Roundtable 2 on Safe Harbours on February 29

In the second Roundtable, a Deloitte team shared how they approached Pillar Two readiness with their clients, and the 5 step process covering:

• determining scope,
• calculating GloBE income,
• determining covered taxes,
• calculating ETR and Top-up Tax and
• applying the IIR and UTPR

This 5 step process also incorporated how the various safe harbours would be taken into account (Transitional CbCR Safe Harbour, QDMTT Safe Harbour, Simplified ETR Safe Harbour, De minimis exclusion and the Transitional UTPR Safe Harbour).

Finally, Deloitte shared working examples of a US UPE with a Dutch IPE holding EU and non-EU CEs, and a US GILTI example dealing with the Blended CFC rules.

Schedule Pillar II Roundtables