The Pillar Two GloBE Rules & Insurance Companies
June 3, 2025
May 29, 2025: Kenya – Section 7 of the 2025 Finance Bill (sent to Parliament on May 7, 2025), provides that the DMTT is payable by the end of the fourth month following the end of the fiscal year.
May 28, 2025: Hong Kong – The Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024 was passed by the Legislative Council on May 28, 2025. It now needs to be signed by the Chief Executive and published in the Official Gazette.
May 20, 2025: Hungary – On May 13, 2025, Bill T/11920 was issued (the 2025 Spring Tax Package). This includes a provision to amend the Pillar 2 registration deadline to 2 months after the end of the relevant tax year.
May 16, 2025: Australia – On May 15, 2025, Australia issued updated guidance on the application of Pillar 2, including guidance on how to administer potential amendments to Australian law to address inconsistencies.
May 16, 2025: Bahrain – On May 15, 2025, Bahrain issued Guidance on Administrative Requirements for the DMTT, including Registration, Elections and Payment of tax.
For all Pillar 2 Developments, see our Pillar Two Developments Tracker.
Featured Articles
The GloBE rules include a number of insurance specific adjustments. In this article we look at the nature of these provisions as well as the
Whilst the treatment of investment property for financial accounting purposes is important when determining the GloBE treatment, of even more importance are any differences between
Top-up taxes under a QDMTT are added to covered taxes of a CFC but only for the purposes of calculating the allocation of Blended CFC
The clarifications and additions to the Commentary to the Pillar Two GloBE Rules provided by the OECDs Administrative and Safe Harbours Guidance, means that there
Section 20 of Bill T/11920 of May 13, 2025 (issued as part of the 2025 Spring Tax Package), proposes to amend the registration deadline to
The definition of CFC taxes that are restricted in the GloBE rules is much narrower than under many domestic CFC regimes. In this article we
MNE groups should pay careful attention to any group financing companies in light of the Pillar Two Rules. In this analysis we look at the
Law 3/2025, of 29 April, was published in the Spanish Official State Gazette on April 30, 2025. This amends the Economic Agreement with the Basque
In this article we look at some of the most significant issues to consider including the determination of when and how deals can bring groups
The Pillar Two GloBE treatment of corporate investments will depend to a large extent on the nature of the activities, the accounting treatment and the
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