Session 1

Preparing for the GloBe Information Return: Part I

Tue, April 18, 2023

This session provides an overview of the latest Draft of the much-anticipated GloBE Information Return (GIR) with an emphasis of the CbCR Transitional Safe Harbour Rules.

• Specifically, the OECD’s Focus Group on GloBE Co-ordination, Information, Collection and Exchange (CICE) has released a draft GloBE Information Return (GIR) including an Annex with the data points necessary for tax administrations to evaluate the correctness of a Constituent Entity’s (CE) GloBE tax liability.
• The GIR requires increased data collection and information sharing on a jurisdictional basis. The obligation to prepare the GIR is separate from any local tax return requirements and centers around several groupings of data points necessary to compute the effective tax rate (ETR) for each jurisdiction, including but not limited to the computation of the top-up tax (if any) for each CE, and the allocation of the top-up tax in accordance with the applicable Income Inclusion Rule (IIR) and/or Under Taxed Payment Rule (UTPR).

Learning Objectives

    • Participants will learn the various aspects of the GloBE Information Return (GIR).

    • Participants will understand the mechanics of determining the effective tax rate for Pillar Two purposes including the adjustments for GloBE Income and Covered Taxes.

    • Participants will understand how to determine the CbCR Transitional Safe Harbour including the De minimis, Simplified ETR, and Routine Profits Tests.