Partially-Owned Parent Entity Status and Impacts on Minorities Under Pillar 2
2024 · FISCALITÀ & COMMERCIO INTERNAZIONALE
Within business groups, it is not uncommon to observe the coexistence of minority investors who hold equity interests at certain levels of the corporate structure. If these groups fall within the subjective prerequisite of Pillar 2, under certain circumstances, these minority investors may be required to financially bear a portion of any supplementary taxation arising from the application of the GloBE Rules, even though the entities whose "undertaxed" income they relate to may not be attributable to their minority investment. Without claiming to be exhaustive, we offer some preliminary considerations in this regard in the journal Fiscalità & Commercio Internazionale (No. 11/2024), aiming to provide an overview of this issue and possible ideas for mitigating this area of risk in the interest of minority investors.