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Unpacking Pillar Two: issues and planning for investment portfolios

United Kingdom - July 18 2022 The treatment of investment portfolios under the GloBE rules is likely to prove particularly complex. This will be the case whether the portfolio in…

Lucy Urwin

Unpacking Pillar Two: trust issues

United Kingdom - July 14 2022 The application of the new global minimum tax will create added complexity for groups whose holding structure includes non-corporate entities such as…

Lucy Urwin

Unpacking Pillar Two: transition rules

United Kingdom - July 13 2022 When a group becomes subject to the GloBE rules for the first-time special rules are required to manage pre-existing losses or other timing…

Rhiannon Kinghall Were

Unpacking Pillar Two: intra-group restructuring

United Kingdom - June 8 2022 In this note we look at how the GloBE rules approach business restructuring. While the GloBE rules start by determining an entity's profits and…

Gregory Price, Bezhan Salehy

ATAD 3: what are the consequences of being a shell?

European Union - May 25 2022 The preamble to the European Commission’s Unshell Directive includes four example scenarios setting out the tax consequences for structures that…

Sarah Ling