Pillar Two and the Transitional Rule for Intra-Group Asset Transfers

Journal
International; OECD
Bulletin for International Taxation 2023 (Volume 77), No. 8
In this article, the authors discuss the OECD/G20 Inclusive Framework’s technical guidance for governments on how the 15% minimum taxation under Pillar Two will operate regarding the transitional rule for intra-group asset transfers. They specifically examine cases where corporate taxation on realized capital gains is guaranteed in the exit jurisdiction.