The Japanese National Tax Agency Nov. 6 posted updated FAQs on the global minimum tax for corporate groups. Topics covered include: 1) the 15 percent global minimum tax rate for multinational enterprise (MNE) groups with annual consolidated revenue of at least 750 million euros (US$865.6 million), in accordance with the Global Anti-Base Erosion (GloBE) Model Rules under OECD Pillar Two; 2) the requirements for the transitional country-by-country (CbC) safe harbor provisions for resident constituent entities, for fiscal years between April 1, 2024, and Dec. 31, 2026; 3) calculation procedures, and the rules regarding ownership interests, foreign exchange gains and losses ...
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