Lithuania and Latvia Updates to the GloBE Country Guides
Updates to the GloBE Country Guides for Latvia and Lithuania following the publication of their laws to implement Art 50 of the EU Minimum Tax Directive in the Official Gazette.
New Guidance for the GloBE Treatment of Securitization Entities
The Fourth Set of OECD Administrative Guidance (issued on June 17, 2024) includes guidance on the treatment of Securitization Entities.
OECD Issues Clarifications and Amendments to GloBE Flow-Through Taxation
Section 5 of the Fourth Set of OECD Administrative Guidance (published on June 17, 2024) provides clarifications on the allocation of both profits and taxes of Flow-through Entities (including both hybrid entities and reverse hybrid entities). Most of these changes are to ensure the consistent matching of income and taxes in the same entity.
The Transitional Qualification Mechanism for IIRs and Domestic Minimum Taxes
On June 17, 2024, the OECD provided more information on the Transitional Qualification Mechanism for determining the qualified status of IIRs and Domestic Minimum Taxes
OECD Provides More Guidance on GloBE Carrying Values and Separate GloBE Deferred Tax Calculations
Section 2 of the Fourth Set of OECD Administrative Guidance (issued on June 17, 2024) provides details of the use of GloBE carrying values and the impact that these will have on the GloBE ETR calculation.
Analysis of the Application of the DTL Recapture Rule in the OECDs June 2024 Administrative Guidance
Section 1 of the Fourth Set of OECD Administrative Guidance (issued on June 17, 2024) provides further details on the deferred tax liability recapture rule. Read our detailed analysis.
OECD Issues Fourth Set of Administrative Guidance
On June 17, 2024 the Fourth set of OECD Administrative Guidance was issued. This includes guidance related to the recapture rule applicable to deferred tax liabilities, cross-border allocation of current and deferred taxes, flow-through entities and securitisation vehicles.
Spanish Parliament Publishes Draft GMT Law
On June 14, 2024, the Official Gazette of the Spanish Parliament published the draft law to implement the EU Minimum Tax Directive. The draft law includes minor changes from the version published in December 2023.
GloBE Country Guide: Singapore
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Singapore for accounting periods beginning on or after January 1, 2025.
Luxembourg Government Approves Draft Law to Include Additional OECD Administrative Guidance
On June 5, 2024, the Luxembourg Government adopted the draft law amending the law of 22 December 2023 on the minimum effective taxation for multinational enterprise groups and large domestic groups. The draft law provides for a number of amendments in the December 2023 OECD Administrative Guidance.
