Australia Treasury Seeks Comments on Draft Amendments to Global Minimum Tax Rules Under Pillar 2

The Australian Treasury May 1 opened a consultation on draft amendments to the global minimum tax pursuant to the Global Anti-Base Erosion (GloBE) rules under OECD Pillar Two. The draft amendments include measures to: 1) modify the income allocation rules for flow-through entities; 2) expand the blended controlled foreign corporation (CFC) allocation key to include permanent establishments (PEs), and treat non-GloBE entities and PEs as constituent entities of multinational enterprise (MNE) groups; 3) adjust the total deferred tax adjustment calculations to consider different substitute loss carryforward deferred tax asset (SLCF DTA) categories; 4) extend the transitional country-by-country (CbC) reporting safe ...