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From the draft legislation issued to date, the commencement date for the Pillar Two GloBE Rules varies amongst jurisdictions. The current proposals for Singapore, Hong Kong and Thailand are based on a 2025 commencement date for their Income Inclusion Rule, but even amongst other jurisdictions with a 2024 commencement date, the precise wording differs.
For instance, the wording can vary from ‘ On or after December 31, 2023’, ‘From December 31, 2023’ or ‘After December 30, 2023’ to ‘From January 1, 2024’ or ‘From April 1, 2024’.
The current commencement dates from draft legislation issued are:
| Country | Start Date | Analysis |
|---|---|---|
| United Kingdom | Accounting periods beginning on or after December 31, 2023 | GloBE Country Guide: The United Kingdom |
| Germany | Accounting Periods beginning after December 30, 2023 | GloBE Country Guide: Germany |
| Japan | Accounting Periods beginning on or after April 1, 2024 | GloBE Country Guide: Japan |
| The Netherlands | Accounting periods beginning from December 31, 2023 | GloBE Country Guide: The Netherlands |
| Switzerland | Accounting Periods beginning on or after January 1, 2024 | GloBE Country Guide: Switzerland |
| Sweden | Accounting periods beginning after December 31, 2023 | GloBE Country Guide: Sweden |
| South Korea | Accounting Periods beginning on or after January 1, 2024 | GloBE Country Guide: South Korea |
In practice, the above draft legislation may well effectively apply the Pillar Two GloBE Rules from January 1, 2024 for pretty much all in-scope MNEs (aside from in Japan). Nevertheless, there is a difference, and one reason for the potential discrepancy in the wording is interesting.
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