The Impact of Pillar 2 on Group HR/Payroll Companies
March 10, 2025
Featured Articles
Centralized HR/payroll companies are frequently used by MNE groups but raise specific issues in relation to the Pillar Two GloBE Rules. In particular, the impact
Jurisdictions that apply a territorial basis do not tax foreign source income. This raises some interesting issues in the application of the Pillar 2 rules.
On February 20, 2025, Gibraltar issued the Income Tax (Allowances, Deductions, and Exemptions) (Amendment) Rules 2025 to allow in-scope MNEs to just be taxed under
In this article we look at the interaction between deferred tax on bonus depreciation and the substance-based income exclusion on investments in tangible assets.
On February 15, 2025, Law 2025-127 of February 15, 2025 (the 2025 Finance Act) was published in the French Official Gazette. This includes a number
Foreign tax credits interact with the Pillar Two GloBE Rules in a number of ways. In this article we assess the key impact.
The Pillar Two rules don’t just apply to companies. They apply to ‘entities’. This means that the Pillar Two GloBE rules can apply to both
Pension funds are subject to a number of specific provisions under the Pillar Two rules. In this article we look at some of the key
On February 12, 2025, Poland issued a list of jurisdictions that have qualified status for the purposes of the income inclusion rule and domestic minimum
In January 2025, the OECD provided some much-needed guidance on the operation of the Pillar 2 GloBE rules. This Orbitax article provides an analysis of
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