Global tax reform: thin end of the wedge for multinational SMEs?

Auteur: Jelle R. Bakker

10 november 2021

Jelle Bakker, of Bentacera in The Netherlands, has written a piece on global tax reform for Accountancy Daily. The article reflects on how new rules might effect SMEs.

Global tax: pillar one

Pillar One will initially apply only to multinational enterprises with a global turnover of more than €20bn and a pre-tax profit margin above 10%.

The Pillar One rules would allocate more profits to markets with whom the businesses interact, regardless of their physical presence there. This Pillar also aims at developing a new non-physical presence nexus rule not dependent on physical presence but largely based on sales. In addition, new profit allocation methods going beyond the arm’s length principle are introduced. These methods include:

  1. a modified residual profit split method that would allocate to market jurisdictions a portion of a multinational’s non routine profit (which is not recognised under the current profit allocation rules);
  2. a fractional apportionment method, allocating profits based on a formula that may consider relevant factors such as employees, assets, sales and users; and
  3. distribution-based approaches that could consider both non-routine and routine profits arising from activities associated with market and distribution.

Global tax: pillar two

Based on the Pillar Two rules, multinational groups with a global annual turnover above €750m should be subject to a minimum effective tax rate of 15% in every jurisdiction where they realise profits.

Conclusion

On the face of it, SMEs will likely not be affected by the Pillar One and Two rules, given the high thresholds set for application. However, in the near future Pillar One and Two could prove to be the thin end of the wedge, with the new Pillar standards ultimately becoming the SME standards both in the EU and the world over.

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International Tax Specialist and Tax Director of Kreston Europe

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