A detailed analysis by Alvarez and Marsal
REITs and real estate investment funds that meet the EUR 750 million revenue threshold are in principle carved-out of the scope of Pillar 2.
Pillar 2 is becoming a reality in Europe, REITs and real estate funds with entities and investments in several European countries are recommended to assess the impact of the OECD’s Pillar 2 Model Rules, starting with whether they are in scope.
The OECD’s Pillar 2 Model Rules – also referred to as the Anti Global Base Erosion Rules (GloBE Rules) – are in essence a system of top-up taxes to ensure that certain cross-border groups – referred to as multinational enterprises (MNEs) – pay at least 15% tax in the jurisdictions where their effective tax rate (ETR) is lower.
Our UK firm, Alvarez and Marsal, explore the various carve-outs that are relevant for the real estate investment industry and share their views on items that are unclear.
Continue reading here.
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