The Liechtenstein Official Gazette April 3 published Regulation No. 640.21, amending the Global Anti-Base Erosion (GloBE) regulations on the global minimum taxation of large corporate groups under the OECD’s Pillar Two. The regulation includes measures: 1) specifying that supplementary taxes may be determined based on OECD base erosion and profit shifting (BEPS) Inclusive Framework provisions on transitional country-by-country (CbC) reporting safe harbor arrangements, qualified domestic minimum top-up tax (QDMTT) arrangements, side-by-side safe harbor regimes, ultimate parent entity (UPE) safe harbor regimes, the substance-based tax incentives safe harbor, and simplified effective tax rate (ETR) safe harbor regimes; and 2) applying the ...
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