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e20220531 BEPS 2.0 Pillar 2 – Issues for applying the global minimum tax for Hong Kong businesses
Description
Please be reminded that this is an e-seminar which can be accessed anytime to obtain the CPD hours.
Subsequent to the release of the GloBE Model Rules in December last year for implementing the 15% global minimum tax, the OECD issued the detailed Commentary and Illustrative Examples on the GloBE Rules in March 2022 to provide comprehensive technical guidance on the interpretation and application of the GloBE rules. The lengthy Commentary includes elaboration on each article of the GloBE Rules whereas the Illustrative Examples provide examples on selected articles of the GloBE Rules. In this webinar, the speakers will:
- Discuss the common issues for applying the GloBE Rules relevant to the businesses in Hong Kong, taking into account the guidance in the Commentary, including:
- deferred tax attributes and effective tax rate calculation;
- treatment of losses;
- excluded dividends and excluded equity gains; and
- holding structures with minority-owned entities, joint ventures or minority interests, and
- Special issues for shipping leasing and aviation businesses
- Discuss a list of other issues clarified in the Commentary
- Highlight some of the remaining uncertain areas