Hungary Includes GloBE Amendments in its 2024 Autumn Tax Proposal
On October 29, 2024, Hungary issued its Autumn Tax Package proposal. This included minor changes to the Pillar Two law. Most notably it expanded on the registration requirements.
Pillar Two: STTR Implementation
We keep track of the domestic implementation of the Subject-to-Tax Rule (STTR) internationally including links to relevant effected double tax treaties.
Hong Kong Issues Outcome of the Consultation on the Introduction of the GloBE Rules
On October 30, 2024, the Hong Kong government released the outcome statement following the previous consultation into the introduction of the GloBE rules.
Uk GloBE Country Guide Updated for 2024 Budget Provisions
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 provision for a foreign QDMTT to qualify for the QDMTT Safe Harbour if it is reasonable to conclude that it is likely to fall within the OECD guidance. Read our updated UK GloBE Guide for more information.
New: Isle of Man GloBE Country Guide
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 January 1, 2025. Updated for the draft legislation issued by the Income Tax Division on October 24, 2024.
GloBE Country Guide: Isle of Man
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 January 1, 2025. Updated for the draft legislation issued by the Income Tax Division on October 21, 2024.
Isle of Man Issues Draft Legislation for the IIR and QDMTT from 2025
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. The draft legislation will be considered by the Parliament in November 2024.
EU Issues DAC 9 Proposal for Centralised GIR Filing Within the EU
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 reflect the OECD Model Rules so that MNEs would only have to file one GIR, at central level, for the entire group.
Italy Issues SBIE Decree to Implement the July 2023 and June 2024 OECD Administrative Guidance
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 all of the OECD Administrative Guidance on the SBIE.
Jersey GloBE Guide Updated for Final Enacted Law
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 Income Tax (Jersey) Law 202 (the ‘MCIT law’), to provide for the IIR and MCIT from January 1, 2025. Read our updated GloBE Country Guide.
