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Direct Transposition of the GloBE Rules: Different Approaches By Switzerland & New Zealand

Both New Zealand and Switzerland have issued draft legislation to implement the Pillar Two GloBE Rules domestically.
 
The general approach taken by both is to transpose the OECD Model GloBE Rules into domestic law by way of a direct reference, in order to reduce the risk of interpretive errors and mismatches between the GloBE rules as adopted in other countries and as implemented domestically. There are then some slight amendments to tailor the rules to their income tax systems.
 
However, whilst both jurisdictions are opting for direct transposition of the OECD Model Rules, there is a key difference in how they are drafted (and how the GloBE Rules apply domestically). 
 

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Picture of Lee Hadnum

Lee Hadnum

Lee is a qualified Chartered Accountant and Chartered Tax Adviser. A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

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