| BEPS 2.0 | BEPS 2.0 is a global tax reform initiative developed by the OECD to address Base Erosion and Profit Shifting (BEPS) practices that cost countries an estimated 100-240 billion USD in lost revenue annually.
BEPS 2.0 is composed of two parts, Pillar One and Pillar Two. |
| CbC - Country by Country reporting | Country-by-Country Reporting is a tax transparency initiative developed by the OECD as part of its Base Erosion and Profit Shifting (BEPS) Action Plan |
| CbCr - Country by Country report | A Country-by-Country Report is a report providing local tax authorities with visibility into revenue, income, tax paid and accrued, employment, capital, retained earnings, tangible assets, and activities. This information is shared with tax administrations in the jurisdictions where the MNE operates, for use in high-level transfer pricing and BEPS risk assessments. |
| GILTI - Global Intangible Low-Taxed Income | GILTI is an Income inclusion under Section 951A related to a type of income earned by CFCs and subject to a preferential tax rate through an additional deduction under Section 250. |
| GIR - GloBE Information Return | The GloBE Information Return is a standardized return developed as part of the OECD's Pillar Two initiative. The GIR provides information on the tax calculations made by the multinational enterprise (MNE) group and contains the information a tax administration needs to evaluate the correctness of a Constituent Entity's GloBE tax liability and to perform an appropriate risk assessment. |
| GloBE - Global Anti-Base Erosion | GloBE is a component of the OECD's Pillar Two initiative. The GloBE rules aim to ensure that large multinational enterprises (MNEs) pay a minimum level of tax on the income arising in each jurisdiction where they operate. |
| GMT - Global Minimum Tax | Global Minimum Tax establishes a 15% effective tax rate based on the financial accounts of multinational enterprises with annual revenues above €750 million on a jurisdiction-by-jurisdiction basis. |
| IFRS - International Financial Reporting Standards | IFRS is a set of accounting standards used in over 140 countries worldwide, except for the United States, which govern how financial information should be reported in financial statements. |
| IIR - Income Inclusion Rule | The IIR is a rule which requires a parent entity to include a share of income from subsidiaries located in a low-tax jurisdiction when calculating a top-up tax under Pillar Two. |
| MNE - Multinational Enterprise or MNC - Multinational Corporation | A MNE is a company that has business operations in at least one country other than its home country. By some definitions, it also generates at least 25% of its revenue outside of its home country. |
| OECD - Organisation for Economic Co-operation and Development | The OECD is an international organization of member countries which work together to develop policy standards to promote sustainable economic growth. |
| OTP - ONESOURCE Tax Provision | ONESOURCE Tax Provision is a web-based software developed by Thomson Reuters to assist with the calculation needs inherent in financial accounting and reporting of income taxes. It is designed to provide comprehensive calculations for federal, state, local, and international jurisdictions, offering scalability and customization to meet the specific requirements of users |
| Pillar Two (or Pillar 2) | Pillar Two is a global minimum tax directive under the OECD that aims to ensure large multinational enterprises (MNEs) pay a minimum level of tax on the income arising in each jurisdiction where they operate. |
| QDMT - Qualified Domestic Top-up Tax | The QDMTT is a minimum tax included in domestic law to increase domestic tax liability to a minimum rate, as defined by Article 10 of the OECD Pillar Two Model Rules. |
| STTR - Subject to Tax Rule | The STTR is a treaty-based rule that allows source jurisdictions to impose an additional tax liability on certain intra-group payments in case the recipient is subject to a nominal corporate tax rate below a certain threshold, which is generally 9%. |
| Subpart F | Subpart F is a type of income earned by a CFC, as defined under Section 952. This type of income gives rise to an income inclusion under Section 951. |
| US GAAP - Generally Accepted Accounting Principles | US GAAP is a set of accounting rules, standards, and procedures used in the United States. GAAP aims to improve the clarity, consistency, and comparability of the communication of financial information. |
| UTPR - Undertaxed Profits Rule | The UTPR acts as backstop to the IIR which collects necessary top-up tax which was not collected under an IIR. |
