Group Financing Companies and Pillar Two
November 6, 2024
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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
On October 30, 2024, the Hong Kong government released the outcome statement following the previous consultation into the introduction of the GloBE rules.
The UK 2024 Budget on October 30, 2024 confirmed a number of proposed amendments to the application of the Pillar Two GloBE rules including a
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in the Isle of Man for accounting periods beginning on or after
On October 24, 2024, the Isle of Man (‘IOM’) income tax division published the draft legislation to implement the IIR and QDMTT in the IOM.
On October 28, 2024, the EU Commission adopted a proposal to amend the Directive on administrative cooperation in the field of taxation (DAC 9) to
On October 15, 2024, Italy issued Decree 11, of October 2024 on the calculation of the Substance-based Income Exclusion (SBIE) under Pillar 2. This includes
On October 22, 2024, Jersey enacted the Multinational Taxation (Global Anti-Base Erosion – IIR Tax) (Jersey) Law 202 (the ‘IIR law’) and the Multinational Corporate
On October 17, 2024, Germany released its Group Parent notification form for German minimum tax groups. Section 3 of the German GMT law provides that
On October 22, 2024, Jersey enacted the Multinational Corporate Income Tax (Jersey) Law 202 and the Multinational Taxation (Global Anti-Base Erosion – IIR Tax) (Jersey)
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