This article examines the treatment of year-end transfer pricing adjustments under the GloBE rules, comparing Italian and US approaches and highlighting the asymmetries that arise when adjustments are recognized only for tax purposes. It analyses how these discrepancies affect GloBE Income, covered taxes and the effective tax rate; and it discusses the resulting risks of double taxation or non-taxation. The authors propose clarifications and solutions, including alignment mechanisms and recent developments under the Side-by-Side (SbS) package.
Tombesi et al. (Fri,) studied this question.