The July statement provided that the global anti-base erosion (GloBE) rules, including the undertaxed payments rule, should be enacted by jurisdictions in 2022 to become effective in 2023. Regarding Swiss concerns about the pace of the implementation timeline, Cormann said that the OECD is considering deferring implementation of the undertaxed payments rule to address such concerns. He added that the rate has РІР‚Сљnot yet been agreedРІР‚Сњ and Switzerland may argue for a higher payroll carve-out. In the letter to the Swiss government, Cormann stated that the final rate for the substance carve-out from the minimum tax for tangible assets and payroll, which was deemed РІР‚Сљat least 5%РІР‚Сњ in the July statement, remains РІР‚Сљone of the key outstanding issues to be resolved by October.РІР‚СњР”В¬ormann explained in the letter that the substance carve-out for payroll was intended to address the concerns of countries seeking special treatment for research and development (R&D) costs, even though the carve-out included was not limited as to the type of activities that would qualify. The Irish government has indicated it might be willing to abandon its opposition to the tax deal if the РІР‚Сљat leastРІР‚Сњ language is removed.Р”В¬ountries are seeking enhanced substance carve-outs from the 15% tax rate as well, and the rate of such carve-outs is also in contention. Ireland had similarly expressed concerns about the РІР‚Сљat leastРІР‚Сњ language in the agreement, which suggests the potential for a higher rate down the road if not initially. OECD Secretary-General Mathias Cormann told the Swiss Finance Minister that he personally does not see a consensus on a global minimum tax at a rate above 15%, attempting to allay Swiss concerns about the Inclusive FrameworkРІР‚в„ўs July statement referring to a rate of РІР‚Сљat leastРІР‚Сњ 15%, in an August 30 letter published this week by the Swiss government.Р”Р„lso this week, the Irish government has reportedly received the text for a revised agreement from the OECD, according to an October 4 article in the Irish Times.

Disclosure of deferred tax asset