When
Tuesday, 18 February 2025
Time
10.00 - 12.00 / 13.00 - 15.00
Venue
Online
Speakers
Dr Christopher Bergedahl
Graziella Demanuele Bianco

The components of the Jurisdictional ETR

The below two sessions are part of the The MIT Series: Global Minimum Tax Rules which commenced on 11th February 2025.

 

Tuesday, 18 February 2025, 13:00 – 15:00

GloBE Income or Loss

During this session the speaker shall delve into:

  • Departure point: Financial Accounting Net Income or Loss (FANIL)
  • Article 3.1.2. Adjustments
  • Treatment of Main Entities vs. PEs + PE loss importation / recapture rules
  • Arm’s length adjustments
  • Intra-Group Financing exception
  • International Shipping Income Exclusion
  • Elections (Realisation election, Aggregate Asset Gain or Loss election)

 

Wednesday, 12 March 2025, 10:00 – 12:00

Adjusted Covered Taxes

In this session, speaker shall go through

  • Departure point: Current tax expense as per financial accounts
  • Notion of Covered Taxes with specific reference to DRIT. − Total Deferred Tax Adjustment Amount
  • Deferred Tax Recapture Rules
  • Allocation of Covered Taxes to Constituent Entities (incl. Blended CFC Tax Rule)
  • GloBE Loss Election

 

MEMBERS ARE ENTITLED TO 2 COMPLIMENTARY CPE EVENTS.

To claim the offer for this webinar select ‘MIT Members – Membership Offer’ as the price option. A participant’s eligibility for the offer claimed is subject to final confirmation by the Malta Institute of Taxation – Terms & Conditions Apply


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4 CPE Core Hours

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Dr Christopher Bergedahl

Christopher is a Director at Deloitte Malta within the Tax service line. He specialises in working with multinational clients providing support on financing, IP and value chain alignment projects. More recently, he has been involved in supporting Malta-based clients impacted by the global minimum taxation framework. He graduated summa cum laude in 2017 from the International Tax Center Leiden following which he served as a Teaching Assistant for the Fall Term of the 2017-2018 class. Christopher is warranted to practice in front of the Superior Courts of Malta and is a member of the Malta Institute of Taxation, the Malta Branch of the International Fiscal Association and the Malta Institute of Financial Services Practitioners. Furthermore, Christopher is the Chairperson of the International Tax Sub-Committee of the MIT’s Direct Tax Committee.

 

Graziella Demanuele Bianco

Graziella is a Certified Public Accountant and an Associate Director at KPMG with over 15 years’ experience advising a wide range of clients on direct and indirect tax matters. For the past 6 years, she acted as the firm’s Tax Knowledge Manager following developments in the fiscal world, providing technical interpretations of tax laws, drafting position papers, delivering inhouse training and contributing to technical working groups both locally and within KPMG‘s international network. Graziella is currently also a member of the Indirect Tax Committee of the Malta Institute of Taxation.