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CA Final · Direct Tax Laws & International Taxation · Latest Developments in International Taxation

Pillar Two GloBE rules apply to multinational enterprise groups whose consolidated revenue meets a specified threshold. Meridian Foods Group has consolidated revenue of EUR 600 million in at least two of the four preceding years. Which statement is correct?

The group is outside the GloBE rules. The Pillar Two revenue threshold is EUR 750 million of consolidated revenue in at least two of the four preceding years, and EUR 600 million falls short of it. Listing status or having a permanent establishment does not affect applicability.

  1. AThe group is outside the GloBE rules because the threshold is EUR 750 millionCorrect
  2. BThe group is within the GloBE rules because the threshold is EUR 500 million
  3. CThe group is within the rules only if it has a permanent establishment in India
  4. DThe group is outside the rules unless it is listed on a stock exchange

Explanation

GloBE applies to MNE groups with annual consolidated revenue of at least EUR 750 million in at least two of the four preceding fiscal years. EUR 600 million is below this, so the group is not in scope. EUR 500 million is not the threshold, and listing or PE status is irrelevant to the test.

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