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The potential impact of Pillar Two on tax incentives Niels Bammens & Dieter Bettens

By: Bammens, Niels.
Contributor(s): Bettens, Dieter.
Material type: ArticleArticleSubject(s): FISCALIDAD INTERNACIONAL | IMPUESTO DE SOCIEDADES | SEGUNDO PILAR (OCDE) | TIPO MÍNIMO GLOBAL | INCENTIVOS FISCALES In: Intertax v. 51, n. 2, February 2023, p. 155-169Summary: The article examines the potential implications of the Pillar Two rules for corporate income tax incentives in countries’ domestic laws. Section 2 provides an overview of the Pillar Two rules. Section 3 highlights their features that are most relevant from the perspective of domestic tax incentives, specifically, the substance based carve-out and domestic top-up taxes. Section 4 discusses potential policy implications of the Pillar Two rules regarding domestic tax incentives after which section 5 addresses a number of specific tax incentives in more detail.
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Resumen.

The article examines the potential implications of the Pillar Two rules for corporate income tax incentives in countries’ domestic laws. Section 2 provides an overview of the Pillar Two rules. Section 3 highlights their features that are most relevant from the perspective of domestic tax incentives, specifically, the substance based carve-out and domestic top-up taxes. Section 4 discusses potential policy implications of the Pillar Two rules regarding domestic tax incentives after which section 5 addresses a number of specific tax incentives in more detail.

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