Top-up Tax Law for Multinational Enterprise Groups

Top-up Tax Law for Multinational Enterprise GroupsArticle 9

Top-up Tax Law · Matters for the Executive Regulation

Subject to the provisions of this Law, the Global Anti-Base Erosion Rules and the relevant supporting documents issued by the Organisation for Economic Co-operation and Development, the Regulation must prescribe, in particular, the following: 1. The mechanism for calculating Top-up Tax and the provisions relating to safe harbours. 2. The controls governing the treatment of permanent establishments that are Constituent Entities as separate from the main entity and from the permanent establishments belonging to it. 3. The other rules, controls and procedures necessary to implement this Law.

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