December 29, 2023: Finland
On December 28, 2023, the Finnish President approved the ‘Law on the Minimum Taxation for Corporations’, which implements the EU Minimum Tax Directive.
https://valtioneuvosto.fi/delegate/file/132595
December 29, 2023: Italy
On December 28, 2023, the Italian Official Gazette published Legislative Decree No. 209 of December 27, 2023 which implements the EU Minimum Tax Directive.
Official Journal (gazzettaufficiale.it)
December 27, 2023: The Netherlands
On December 27, 2023, the Dutch Official Gazette published the 2024 Tax Plan which includes the Minimum Tax Act to implement the EU Minimum Tax Directive.
December 27, 2023: Luxembourg
On December 22, 2023, the Luxembourg Official Gazette published Law A864 to transpose the EU Minimum Tax Directive.
Loi du 22 décembre 2023 relative à l’imposition… – Legilux (public.lu)
December 27, 2023: Germany
Today, Germany’s law to implement the Pillar 2 GloBE Rules/EU Minimum Tax Directive was published in the Federal Law Gazette 2023 I No. 397 of 27.12.2023.
December 27, 2023: France
On 21 December 2023, the French Parliament approved the Finance Bill for 2024.
Aside for the constitutionality review by the French Constitutional Council, the Bill is final.
Projet de loi de finances n°1680 – 16e législature – Assemblée nationale (assemblee-nationale.fr)
December 22, 2023: EU
Today, the EU issued a FAQ document covering key Q&A’s on the EU Minimum Tax Directive:
20231222 Pillar 2 technical FAQ.pdf (europa.eu)
December 22, 2023: Switzerland
Today the Swiss Federal Council announced Switzerland is to apply a QDMTT from December 31, 2023. The IIR and UTPR are to be delayed:
Introduction of OECD/G20 minimum tax rate with effect from 1 January 2024 (admin.ch)
December 22, 2023: UK
On December 21, 2023, the UK issued detailed draft guidance on various aspects of the UK’s multinational top-up tax, including how to calculate the ETR.
Draft guidance on Multinational Top-up Tax and Domestic Top-up Tax – GOV.UK (www.gov.uk)
December 21, 2023: Gibraltar
On December 19, 2023, Gibraltar announced it is bringing forward its QDMTT to apply from December 31, 2023. This was previously intended to apply from December 31, 2024.
In early 2024, legislation to implement the QDMTT is to be issued.
878.1-2023.pdf (gibraltar.gov.gi)
December 21, 2023: Luxembourg
On 20 December 2023, the Luxembourg Parliament voted to approve the draft law n°8292 transposing the EU Council Directive.
https://www.chd.lu/fr/dossier/8292
December 21, 2023: Hong Kong
Today the Hong Kong Inland Revenue Department launched a consultation on the design of a global minimum tax and the HKMTT (a QDMTT). This is subject to a consultation until March 20, 2024.
The Government targets to introduce the legislative amendments into the Legislative Council in the second half of 2024.
Consultation paper_Global minimum tax and HKMTT (Eng).pdf (fstb.gov.hk)
December 20, 2023: Sweden
On December 16, 2023, the Swedish Official Gazette published Law No. SFS 2023:875, implementing the EU Minimum Tax Directive.
December 20, 2023: Spain
Yesterday, Spain’s Council of Ministers approved a draft law to implement the EU Minimum Tax Directive. It is to be subject to a consultation and then sent to Parliament.
The draft law includes an IIR, UTPR and QDMTT.
December 20, 2023: Romania
Yesterday, the Romanian Parliament approved the ‘Draft Law on ensuring a global minimum level of taxation for MNE Groups and Large National Groups’. It now requires Presidential approval.
December 19, 2023: The Netherlands
Today, the Dutch Senate approved the 2024 Tax Plan which includes the Minimum Tax Act to implement the EU Minimum Tax Directive.
Belastingplan 2024 (36.418) – Eerste Kamer der Staten-Generaal
December 18, 2023: OECD
Today, the OECD issued the Third Set of Administrative Guidance on the Pillar Two GloBE Rules. It covers:
-Purchase price accounting adjustments in Qualified Financial Statements
-Further Guidance on the Transitional CbCR Safe Harbour
-Administrative Guidance on application of GloBE Rules
-Further Administrative Guidance on the allocation of Blended CFC Taxes
-Transitional Filing Deadlines for MNE Groups with Short Reporting Fiscal Years
-Simplified Calculation Safe Harbour for Non-Material Constituent Entities
We are preparing a detailed analysis for site members.
December 18, 2023: Sweden
On December 13, 2023, the Swedish Parliament approved the law to implement the EU Minimum Tax Directive:
December 15, 2023: Germany
Today, the Bundesrat (Germany’s Upper House of parliament) passed the ‘Act on the implementation of Council Directive (EU) 2022/2523 to ensure a global minimum level of taxation and further accompanying measures’ (the Global Minimum Tax Act). It requires Presidential approval for enactment.
December 15, 2023: Denmark
The Danish Minimum Taxation Act was enacted as Law No. 1535 of December 12, 2023.
Minimum Taxation Act (retsinformation.dk)
December 14, 2023: Austria
Today, the Austrian National Council passed the Draft Pillar Two Law:
Sitzung des Nationalrats vom 14. Dezember 2023 (245/NRSITZ) | Parlament Österreich
December 13, 2023: Bulgaria
Today, the Bulgarian Parliament approved the amendments to the Corporate Income Tax Act to implement the Pillar 2 GloBE rules.
The law needs to be signed by the President to be enacted.
Новини – Народно събрание на Република България (parliament.bg)
December 13, 2023: Malaysia
Today, the Malaysian Parliament approved the Finance Bill (No.2) 2023. This includes an income inclusion rule (IIR) (referred to as the ‘Multinational Top-Up Tax’) and a domestic minimum tax (intended to be a Qualified Domestic Minimum Top-Up Tax) from January 1, 2025. The Under-Taxed Profits Rule (UTPR) is not included in the draft law.
The law needs to be approved by the King to be enacted.
DR 36_2023 – BM.pdf (parlimen.gov.my)
December 12, 2023: European Union
On December 12, 2023 the EU Commission published the Commission Notice to Elect to delay application of the IIR and UTPR under Article 50 of the Pillar Two Directive.
It provides that as at December 12, 2023 the following Member States notified the Commission of their intention to elect for a delayed application of the IIR and UTPR:
-Estonia,
-Latvia,
-Lithuania,
-Malta,
-Slovakia.
The jurisdictions still need to implement all the other relevant Pillar Two Directive provisions so as to enable taxpayers and other Member States and jurisdictions to properly apply the system, but this is a scaled down version. To date, Slovakia and Lithuania have issued draft legislation. Slovakia is implementing a QDMTT which results in its legislation transposing more of the GloBE rules.
EUR-Lex – C_202301536 – EN – EUR-Lex (europa.eu)
December 11, 2023: Slovakia
On December 8, 2023, the Slovakian Legislative Council passed the draft Pillar 2 law to implement a QDMTT. There were no amendments to the text during the parliamentary process. The law will be enacted once it has been signed by the President.
nrsr.sk/web/Dynamic/DocumentPreview.aspx?DocID=536934
December 8, 2023: Australia
Australia’s 2023 Parliamentary term has now ended. The Pillar 2 law has not yet been issued as an exposure draft or introduced to Parliament. The next Parliamentary sitting is February 6, 2024. The law is proposed to be effective from January 1, 2024, therefore, the legislation when finally enacted may have to have retrospective effect.
December 7, 2023: Belgium
On November 30, 2023, the Belgian House of Representatives adopted the draft law No. 55K3678 to implement the EU Minimum Tax Directive. As the monocameral procedure under Article 74 of the constitution applies, the law does not need to be approved by the Senate). The law will be enacted after it has been promulgated by the King and published in the official journal.
The draft law was passed with no amendments.
The Belgian Chamber of Representatives (dekamer.be)
See our previous review:
https://oecdpillars.com/a-review-of-belgiums-draft-pillar-two-law/
December 6, 2023: Slovakia
On December 4, 2023, the Government approved the ‘Draft Act on the Equalization Tax to ensure a minimum level of taxation for multinational enterprise groups and large national groups’. It also approved a proposal for an accelerated legislative procedure to enact the law. The draft law has now been passed to the Legislative Council.
The draft law includes a QDMTT.
The Slovak Republic has made use of the derogation under Article 50(1) of the EU Minimum Tax Directive, whereby it decided not to apply the income inclusion rule and the under-taxed profits rule for six consecutive accounting periods starting from 31 December 2023. The Slovak Republic has fulfilled the condition under Article 50(1) as there are no more than twelve UPEs falling within the scope of the Directive in the Slovak Republic.
GOVERNMENT: Communiqué of the 7th Cabinet Meeting – Public Affairs (veci-verejne.sk)
Slovakia’s GloBE Law Applies the EU’s IIR/UTPR Postponement Provision
December 5, 2023: Hungary
Act LXXXIV of 2023 on ‘Additional taxes ensuring a global minimum tax level and amending certain tax laws in connection with this’ was published in issue 171/2023 of the Hungarian Gazette:
https://magyarkozlony.hu/dokumentumok/59ba20495cd587e54decf5b41b0e6f9e4bba3926/megtekintes
This enacts the EU Minimum Tax Directive into Hungarian Law with the IIR and QDMTT applying for accounting periods beginning on or after December 31, 2023.
See our analysis of the changes to the draft law:
Hungary Approves and Updates its GloBE Law » oecdpillars.com
December 4, 2023: Czech Republic
On December 1, 2023, the Czech Parliament approved the Draft Top-up Tax Act to give effect to the GloBE rules. It is now awaiting promulgation by the President.
There were limited amendments to the draft law during the parliamentary process (including the inclusion of the QDMTT Safe Harbour and the Transitional UTPR Safe Harbour, as well as some other key aspects of the July 2023 Administrative Guidance, such as the rules for transferable tax credits).
See our updated GloBE Country Guide: Czech Republic
November 30, 2023: UK
Yesterday, the 2023 Autumn Finance Bill was published. As previously noted it reflects previous draft law issued in July and September 2023 and implements a number of aspects of the OECD Administrative Guidance.
Aside from this it also inserts a new Section 251A which defines what is a qualifying CbC Report.
It states that a CbC Report is “qualifying” if the information relating to the territory is prepared on the basis of qualified financial statements of the multinational group.
Where there is no requirement in a jurisdiction for a CbC report to be prepared and filed, the filing member may include, in the information return in which the election is made, the information that would have been in such a report:
– prepared in accordance with legislation implementing the OECD’s guidance on CbC reporting under the law of the UPE, or
– where there is no such legislation, prepared in accordance with that guidance.
Where this applies, that information is to be treated as if it were a qualifying CbC report for the purposes of the Transitional CbCR Safe Harbour.
November 29, 2023: Vietnam
Today the Vietnamese Parliament passed a Resolution to implement the Pillar Two Global Minimum Tax in Vietnam with effect from January 1, 2024. The Resolution has not yet been publicly issued, however, Parliamentary reports indicate that a domestic minimum tax (intended to be a QDMTT) and an IIR are to be implemented.
A domestic top-up tax return will need to be filed within 12 months after the end of the fiscal year, whilst a GIR and IIR top-up tax return would need to be filed within 18 month of the fiscal year end (15 months in the first year).
If an MNE has more than one constituent entity in Vietnam, it is required to issue a written notice within 30 days from the end of the fiscal year appointing one of the constituent entities in Vietnam to file a declaration and pay the top-up tax.
November 27, 2023: UK
The Autumn Statement on November 22, 2023 confirmed that the Pillar Two GloBE rules will still be implemented in the UK for accounting periods beginning on or after 31 December 2023.
The GloBE rules in the UK (a Multinational Top-up Tax and Domestic Top-up Tax) were introduced in the Spring Finance Act 2023. Further draft legislation was issued on July 18, and September 27, 2023, to provide for the UTPR from 31 December 2024 (at the earliest) and to implement various aspects of the OECD Administrative Guidance (eg see UK Amends 2024 Draft Finance Bill For OECD Administrative Guidance).
In the Autumn Statement, the government confirmed the draft legislation (with only minor changes from the consultation) will be introduced in the Autumn Finance Bill 2023.
Multinational top-up tax and domestic top-up tax — amendments – GOV.UK (www.gov.uk)
November 24, 2023: Norway
Today, the proposal to implement the GloBE rules in Norwegian law from 2024 has been submitted to Parliament.
Unlike the proposal that was circulated for consultation in June, it is now proposed that the introduction be implemented as a separate law (and not a new chapter in the Tax Act).
Norway Sends its Updated GloBE Law to Parliament
Prop. 29 LS (2023–2024) – regjeringen.no
November 24, 2023: UAE
On 24 November 2023, the UAE released Federal Decree Law No. 60 of 2023 (“Decree-Law”), which amends some provisions of the Federal Decree Law No. 47 of 2022 (“CIT Law”).
Article 1 of the Decree-Law states:
– …’ The following will be added to the definition under Article 1 of the CIT Law.
– Supplementary Tax: The supplementary tax imposed on multinational enterprises according to the rules and controls determined by the Council of Ministers in line with Article 3 of this law for the purposes of Pillar 2 Rules issued by the OECD.
– Multinational Enterprise: A multinational enterprise is an entity and/or one or more of its member entities that is located in the country or in a foreign territory as determined by a decision issued by the Board of Directors.
– A new sub-clause is added to Article 3 of the CIT Law as Article 3(3):
Without prejudice to clauses 1 and 2 of this Article, the Council of Ministers shall issue, based on the Minister’s proposal, a decision regulating all cases, terms, conditions, rules, regulations and procedures for imposing the supplementary tax on multinational enterprises and exempting institutions from it, so that the total percentage of the actual tax imposed on them is 15%…’
This therefore provides the basis for future amendments to the CIT law to implement the Pillar 2 Top-up Tax into domestic law. It has already been announced that this will not be in 2024.
November 24, 2023: Austria
Yesterday, the Austrian Government sent the Minimum Taxation Reform Bill to Parliament. The Bill implements the EU Minimum Taxation Directive into domestic law.
The Bill itself includes some amendments from the original Bill for consultation, including the provisions for Marketable Transferable Tax Credits as outlined in the Second Set of OECD Administrative Guidance.
It also includes some proposed changes to the Austrian Commercial Code to exclude the recognition of deferred tax arising under the GloBE rules (either under the domestic Minimum Taxation Reform Bill or a foreign law that implements either the EU Minimum Tax Directive or the OECD Model Rules). See: https://oecdpillars.com/wp-content/uploads/2023/11/imfname_1596481-en.pdf
Minimum Taxation Reform Act – MinBestRefG (2322 d.B.) | Parliament of Austria (parlament.gv.at)
November 22, 2023: Hungary
The draft law to implement the EU Minimum Tax Directive has been approved by the Hungarian Parliament. It was sent to the Hungarian President today for signature.
Hungary Approves and Updates its GloBE Law
Home – Parliament (parlament.hu)
November 20, 2023: Belgium
On November 13, 2023, a draft law to implement the EU Minimum Tax Directive was sent to Belgium’s Parliament. This includes an IIR, UTPR and a QDMTT.
A Review of Belgium’s Draft Pillar Two Law
November 17, 2023: Luxembourg
On November 13, 2023, the Luxembourg Government issued amendments to update its draft law implementing the EU Minimum Tax Directive (Law 8292 issued on August 4, 2023):
Luxembourg Updates its Draft GloBE Law for OECD Administrative Guidance
November 16, 2023: Bermuda
On November 15, 2023, Bermuda issued a third Consultation Paper (including Draft corporate income tax (“CIT”) legislation) to enact a 15% CIT that would be applicable to Bermuda businesses that are part of a Multinational Enterprise Group (“MNE”) with annual revenue of €750M or more. This is modelled on the OECD GlobE rules.
The third consultation period runs from November 15, 2023 to November 30, 2023.
The legislation is expected to be debated in the House of Assembly in December 2023.
Bermuda Issues Draft Corporate Income Tax Law
November 13, 2023: Germany
On November 10, 2023, the Bundestag (lower house) approved the German draft law to implement the EU Minimum Tax Directive.
It will need the approval of the Bundesrat (upper house) and will then need to be signed by the President and published in the Official Gazette to promulgate the enacted law.
Germany Approves and Updates its GloBE Law
German Bundestag – Bundestag votes for the introduction of a global minimum tax
November 10, 2023: EU
On November 9, 2023, the Council of the European Union issued a draft statement addressing possible discrepancies between the Pillar 2 EU Directive and the OECD Model Rules, Commentary and Administrative Guidance.
The European Commission “is of the view that the administrative guidance endorsed by the OECD/G20 Inclusive Framework on BEPS in December 2022, February 2023 and July 2023 is compatible with Council Directive (…)” and the European Council “notes the statement by the European Commission and welcomes, in particular, its view that the administrative guidance endorsed by the Inclusive Framework in December 2022, February 2023 and July 2023 is compatible with the Pillar Two Directive;”
The approach to implementation of the Administrative Guidance in domestic GloBE laws has been haphazard to date with some (eg the Netherlands) having relatively comprehensive implementation, and others (eg Bulgaria) not including the guidance. See our OECD Administrative Guidance Tracker.
https://www.consilium.europa.eu/media/67850/st14732-re01-en23.pdf
November 9, 2023: South Korea
Today, South Korea issued the Preliminary Legislative Notice of Partial Amendment to the Enforcement Decree of the International Tax Mediation Act. Whilst South Korea has previously issued legislation to implement the Pillar Two GloBE rules from January 1, 2024, much of the detail was left outstanding.
The new Amending Decree provides the detail for the operating of the Pillar Two GloBE rules in South Korea. It is open for consultation until December 7, 2023.
https://moleg.go.kr/lawinfo/makingInfo.mo?lawSeq=75288&lawCd=0&&lawType=TYPE5&mid=a10104010000
November 9, 2023: Brazil
It has been reported that Brazil is preparing to implement a Pillar 2 15% Global Minimum Tax.
This was stated by the Secretary of International Affairs of the Ministry of Finance in an interview with Reuters.
November 9, 2023: Vietnam
In Resolution 39/2023, the Vietnamese Parliament has re-added the draft Global Minimum Tax Law for 2023 Parliamentary approval.
In October 2023 it was previously announced that the draft GloBE Law would not be submitted to the next 2023 parliament meeting, making it questionable whether the law would be introduced by the end of 2023.
November 9, 2023: Barbados
On 7 November 2023, the Prime Minister of Barbados, delivered a Ministerial Statement to the House of Assembly.
It was announced that effective 1 January 2024, the Income Tax Act, Cap is to be amended to increase the corporation tax rate to 9% (from the current rate of 1%-5.5%). This increased tax rate will impact all corporate entities other than insurance entities, shipping entities and small businesses with a gross income at or below BBD$2m, which are registered under the Small Business Developments Act.
With effect from 1 January 2024, a QDMTT will be introduced consistent with the GloBE Rules for in-scope companies.
For subsidiaries and PEs of in-scope MNEs’ constituent entities whose UPE is in a jurisdiction that has introduced an IIR or a UTPR, a top up tax will be imposed on the constituent entities to ensure that they will be subject to an ETR of 15% in accordance with the GloBE Rules.
For in-scope MNEs whose UPE is in a jurisdiction that has not implemented the Income Inclusion IIR or the UTPR, or whose constituent entities are not subject to the IIR or UTPR, the QDMTT will not apply.
The Prime Minister also confirmed that it is intended that the new top-up tax would qualify for the QDMTT safe harbour under the OECD Peer Review Process.
A number of tax credits were announced that are to be designed as Qualified Refundable Tax Credits under the GloBE rules. These include the:
– Qualified Job Credit;
– Research and Development Credit; and
– National Development Credit
EY News Release: Barbados Announces Pillar Two Proposals (businessbarbados.com)
November 8, 2023: Bermuda
In the 2023 Throne Speech on November 3, 2023, the Bermuda Government announced it is planning to introduce a corporate income tax bill to implement the global minimum tax agreement within the next nine months. It stated:
‘…In October 2021 a global agreement was reached to make material changes to the global tax system. It was agreed that a minimum tax would be imposed on large multinational enterprises with over 750 Million Euros of global revenue. Almost 150 countries agreed a framework that would subject such entities to a minimum 15% effective tax rate, applied to the profits in every jurisdiction in which they have a corporate footprint.
After two successful rounds of consultation with the public and particularly with affected industry stakeholders, during this Session the Legislature will be invited to consider an historic Corporate Income Tax Bill to implement the Global Minimum Tax agreement in Bermuda.
Following passage of the principal Act, further amendments to the new global minimum tax regime will incorporate specific Qualified Refundable Tax Credits to provide incentives for investment into Bermuda’s economy from companies who will be subject to the new Global Minimum Tax. These tax credits will provide incentives for international companies in Bermuda to invest in projects that will boost our economy and infrastructure.
This certainty in legislation will maintain Bermuda’s competitiveness as an international business centre and reinforce the Island’s hard-earned reputation for transparency and international financial co-operation.
The implementation of the Global Minimum Tax in Bermuda will be the most fundamental tax reform in Bermuda’s history, and additional revenues that may accrue to the Government must be balanced by a reduction in existing taxes and customs duty to ensure that Bermuda remains competitive and retains our thriving international business sector…’
Throne_Speech_2023.pdf (www.gov.bm)
November 7, 2023: Malaysia
Today, the Finance (No. 2) Bill had its first reading before the Malaysian Parliament. This inserts a new Part XI into the Income Tax Act 1967 to implement the GloBE rules. This includes the IIR and a QDMTT from January 1, 2025. There is no UTPR:
A Review of Malaysia’s Draft Pillar Two Law
https://www.parlimen.gov.my/files/billindex/pdf/2023/DR/DR%2036_2023%20-%20BI.pdf
November 6, 2023: Poland
It is being reported that Poland is unlikely to have domestic legislation in place to enact the Pillar Two global minimum tax by the end of 2023. Although work on the bill has been underway for some time it is increasingly likely it will be presented for public consultation at the beginning of 2024 at the earliest.
https://www.prawo.pl/podatki/globalny-podatek-minimalny-coraz-blizej,523741.html
November 6, 2023: Qatar
Last weeks the General Tax Authority closed its three-day regional workshop in Doha on Pillar Two’s model rules for a 15% global minimum tax, in which OECD officials gave presentations on designing and implementing a QDMTT.
The General Tax Authority is going back to the drawing board after consulting the OECD on the first draft of its rules for implementing a QDMTT. They are to submit an improved version of the draft to the OECD for a second reading. A public consultation on the second draft is also possible.
October 31, 2023: Malta
As expected, in yesterday’s 2024 Budget it was announced that Malta will delay the application of the Pillar 2 IIR and the UTPR, as permitted under Article 50 of the EU Minimum Tax Directive. This permits a postponement of the IIR and UTPR by up to 6 years. It is not expected that a QDMTT will be introduced.
Article 50(2) of the EU Minimum Tax Directive provides that where a UPE is located in a Member State that has elected to apply the deferral, other member states are to ensure that the constituent entities of that MNE group are subject (in the Member State in which they are located), to the UTPR top-up tax amount from December 31, 2023.
October 30, 2023: Lithuania
On October 27, 2023, Lithuania’s Ministry of Finance issued a draft law to implement the EU Global Minimum Tax Directive. However, as Lithuania intends to delay the application of the GloBE rules under Article 50 of the EU directive, the draft law is not comprehensive and only covers limited aspects of the GloBE rules (as required for the application of Article 50):
Lithuania Issues Draft Pillar Two Law & Confirms Postponement
MINIMUM LEVEL OF TAXATION FOR GROUPS OF UNITS ASSURANCE LAW (lrs.lt)
October 30, 2023: EU
On October 27, 2023, it was reported that Benjamin Angel the EU Director of Direct Taxation, confirmed that Estonia, Latvia, Lithuania, Malta, and Slovakia have chosen to delay the implementation of the Pillar Two rules.
This is permitted under Article 50 of the EU Minimum Tax Directive which provides that EU Member States in which no more than 12 UPEs of in-scope MNEs are located may elect not to apply the IIR and the UTPR for six consecutive fiscal years beginning from 31 December 2023 (ie until January 1, 2030).
Where this applies to an MNE group it will still be subject to the GloBE rules, including the UTPR, in other Member States with effect from 31 December 2023.
October 27, 2023: The Netherlands
Yesterday, the Dutch House of Representatives adopted the ‘Wet Minimumbelasting 2024’ which implements the rules of Pillar 2 in the Netherlands. The approval of the Dutch Senate is now required for this to enter into force on January 1, 2024
October 26, 2023: Japan
On October 20, 2023, the Japanese Ministry of Finance released its technical explanation of the Japanese Global Minimum Tax Laws and Regulations.
https://www.mof.go.jp/tax_policy/tax_reform/outline/fy2023/explanation/PDF/p0741-0976.pdf
October 25, 2023: Kuwait
It was reported on October 23, 2023, that Kuwait is considering a comprehensive overhaul of its tax laws from January 1, 2025 to apply a 15 percent corporate tax on the profits of all legal persons, including major international companies. There will be exemptions for small businesses.
The reform is proposed in two stages.
The first stage from January 1, 2025 applies the new regime to major international companies (multinationals) with the continued enforcement of current tax laws. It proposes that this will apply to around 15 multinational companies all of which have annual revenues exceeding 750 million euros.
The second phase applies from January 1, 2026 and applies the new tax regime to all legal persons with the repeal of the current tax laws.
The new corporate tax is among 14 priorities submitted by the government to the parliamentary coordinating committee for adoption in the legislative map for the National Assembly session, scheduled to start on October 31.
Currently under Kuwait Decree No. 3/1955, as amended by Kuwait Law No. 2/2008, Juwait does have a 15% corporate income tax, but this only applies to foreign entities carrying on a trade or business in Kuwait, except entities registered in GCC countries (Kuwait, Saudi Arabia, Bahrain, United Arab Emirates, Oman and Qatar and wholly owned by Kuwaiti /GCC citizens).
This would therefore mean that domestic entities within the scope of Pillar Two could be subject to top-up tax in a foreign UPE/IPE/POPE/Group Entity (depending on the nature and location of group ownership) unless Kuwait implemented a domestic CIT regime (ideally a QDMTT to eliminate any foreign top-up tax).
In Section 8 of the Concluding Statement of the IMF 2023 Article IV Mission to Kuwait (issued on June 5, 2023), the IMF recommended that the 15 percent corporate income tax should be expanded to cover domestic firms, which would bring Kuwait into conformity with the OECD global minimum corporate tax for multinationals: Kuwait: Staff Concluding Statement of the 2023 Article IV Mission (imf.org)
The Council of Ministers is considering the formation of a committee to develop appropriate frameworks for policies related to the Pillar Two global minimum tax.
The requirements necessary for Pillar Two implementation were identified as:
Firstly: join the BEPS Inclusive Framework.
Secondly: Undertake a detailed consulting review to provide:
1 – A comprehensive study on Pillar 2.
2 – Determine the rules, standards and requirements related to the application of Pillar 2.
3 – Preparing the necessary policies for the implementation of the project in accordance with best international practices.
4 – Preparation of the draft law.
5 – Training on its application.
The indicative list of major consulting firms to provide the review includes PWC, Deloitte, Ernst & Young, KPMG and Baker Tilly.
October 20, 2023: Ireland
On October 19, 2023, the Irish Ministry of Finance released the Finance (No. 2) Bill 2023.
In line with the EU Directive, the draft legislation applies an Income Inclusion Rule (IIR) (and a QDMTT) from fiscal years commencing on or after 31 December 2023, and the Under-Taxed Profits Rule for fiscal years commencing on or after 31 December 2024.
A Review of Ireland’s Draft Pillar Two Law » oecdpillars.com
October 18, 2023: Hungary
On October 17, 2023, Hungary issued a draft bill for the implementation of the EU Minimum Tax Directive into domestic law. This includes an IIR and QDMTT for accounting periods ended on or after December 31, 2023 and the UTPR for accounting periods ended on or after December 31, 2024.
A Review of Hungary’s Draft Pillar Two Law » oecdpillars.com
https://cdn.kormany.hu/uploads/document/f/f8/f87/f87f6a68f34f1a0649b7681908634a8e16266d28.pdf
October 18, 2023: The Netherlands
On 13 October 2023, the Dutch State-Secretary of Finance issued a Bill to amend the Dutch Draft Minimum Tax Bill.
The Draft Minimum Tax Bill (‘Draft Bill’) was originally issued on May 31, 2023 and is still subject to Parliamentary approval.
The latest amendments primarily include relevant provisions from the February 2023 and July 2023 OECD Administrative Guidance. See:
The Netherlands Issues GloBE Amendments for OECD Administrative Guidance » (oecdpillars.com)
October 17, 2023: Vietnam
The Ministry of Finance was due to finalise the Draft GloBE Law and submit it to the National Assembly for approval at the 6th session.
Today, it was announced that the draft GloBE law will not be submitted to the next parliament meeting that begins next week, making it questionable whether the law will be introduced by the end of 2023. The reason for the delay is the Law on Investment Incentives for Hi-Tech Industries has been delayed and needs to be approved at the same session as the GloBE law.
October 13, 2023: Malaysia
In the 2024 Budget Speech today, the Malaysian Prime Minister confirmed that the Pillar Two GloBE rules are to apply from 2025.
Other jurisdictions applying the GloBE rules from 2025 include:
– Gibraltar
– Jersey
– Guernsey
– Hong Kong
-Isle of Man
– Singapore
– Thailand.
See paragraph 29 of the 2024 Budget Speech:
October 11, 2023: OECD
On October 11, 2023, the OECD released the draft MLC in for Pillar One Amount A.
For the agreement to take effect, 60 countries that are home to at least 30% of the affected multinationals must ratify the agreement, which means that the United States must also join the agreement.
OECD Releases Pillar One Amount A Multilateral Convention » oecdpillars.com
https://www.oecd.org/tax/beps/multilateral-convention-to-implement-amount-a-of-pillar-one.htm
October 11, 2023: OECD
On October 11, 2023, the OECD released the Minimum Tax Implementation Handbook.
The Implementation Handbook is divided into two chapters:
– The first chapter provides an overview of the global minimum tax.
– The second chapter sets out the considerations to be taken into account in assessing implementation options.
https://www.oecd.org/tax/beps/minimum-tax-implementation-handbook-pillar-two.pdf
October 6, 2023: Bermuda
The Government of Bermuda has issued a second public consultation paper regarding the proposed introduction of a corporate income tax to apply to Bermuda businesses that are part of MNE Groups with annual revenue of €750M or more.
Key elements of the policy proposals include:
– Ensuring the policy proposal are aligned with the OECD’s GloBE rules
– Proposing a corporate income tax rate of 15%, which would become effective in 2025
– Developing a robust Qualified Refundable Tax Credit program in 2024 to become effective in 2025
The second consultation period runs from October 5, 2023, to October 30, 2023.
October 5, 2023: Romania
Yesterday, the Romanian Ministry of Finance issued a draft law to implement the Pillar Two GloBE rules/EU Minimum Tax Directive. This includes an IIR and QDMTT for accounting periods ended on or after December 31, 2023 and the UTPR for for accounting periods ended on or after December 31, 2024.
proiectLegeimpozitaremultinationale_04102023.pdf (gov.ro)
October 4, 2023: Cyprus
Yesterday, the Cyprus Ministry of Finance issued the ‘Ensuring a Global Minimum Level of Taxation of Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union Law of 2023’ to implement the Pillar Two GloBE rules/EU Minimum Tax Directive. It is open for consultation until October 31, 2023. This includes an IIR for accounting periods ended on or after December 31, 2023 and the UTPR for accounting periods ended on or after December 31, 2024. The draft law mentions a QDMTT but does not include detailed provisions. The QDMTT is to be effective from January 1, 2025.
Press Office, Announcements , MINISTRY OF FINANCE (mof.gov.cy)
October 4, 2023: Austria
Yesterday, the Austrian Federal Ministry of Finance issued the ‘Federal law enacting the Federal Act to Ensure a Global Minimum Taxation for Groups of Companies’ to implement the Pillar Two GloBE rules/EU Minimum Tax Directive. It is open for consultation until October 20, 2023. This includes an IIR and QDMTT for accounting periods ended on or after December 31, 2023 and the UTPR for for accounting periods ended on or after December 31, 2023.
RIS – BEGUT_22A60527_D2A8_473E_87F5_66E0B98A0D79 – Draft Reviews (bka.gv.at)
October 4, 2023: Japan
On September 29, 2023, the National Tax Agency published the “Partial Revision of the Basic Circular on Corporate Tax” which provides some administrative guidance on various aspects of Japan’s GloBE law.
Japan Issues Circular for Additional GloBE Guidance » oecdpillars.com
October 4, 2023: OECD – STTR
The text of the Pillar 2 STTR Multilateral Instrument has been released by the OECD and the STTR MLI is now open for signature from October 2, 2023. The MLI applies to Covered Tax Agreements, which are existing bilateral tax treaties that are explicitly identified by each of the parties to those tax treaties, and directly amends Covered Tax Agreements in order to implement the STTR.
The STTR MLI is based on the model treaty provision released in July (see: Pillar Two: Subject-to-Tax Rule (STTR) » oecdpillars.com).
There are two new additions:
– Annex IV to the MLI provides that jurisdictions can decide to adopt their specific definition of the term “recognised pension fund” for applying the STTR or use their existing treaty definition;
– Annex V includes an optional circuit-breaker provision that switches off STTR when a developing country becomes a developed country (and switches it on in a reverse case).
Jurisdictions are required to notify the OECD of double tax treaties that they wish to apply the STTR MIL to. In addition further notifications are required if:
– they apply a tax calculated other than on a net income basis (Article 4) (e.g. imposing tax on gross income as a resident jurisdiction or by reference to equity (e.g. a capital tax), or the tax base for which is calculated by reference to multiple components (e.g. income and equity such as zakat)); or
– they do not impose corporate income tax on items of covered income when that income is earned, but instead impose tax at the point of profit distribution (either a deemed profit distribution or an actual distribution) (Article 5).
STTR MLI Explanatory Statement
October 2, 2023: Singapore
In a speech on Friday, the Singapore government reiterated that they are to implement the GloBE rules and a domestic top-up tax for financial years starting on or after 1 January 2025. It was also confirmed that the domestic top-up tax will be designed to qualify for the Qualified Domestic Minimum Top-up Tax Safe Harbour.
September 29, 2023: France
Article 4 of the French 2024 Finance Bill (published on September 27, 2023) includes provisions to implement the EU Global Minimum Tax Directive:
A Review of France’s Draft Pillar Two Law » oecdpillars.com
Finance Bill n°1680 – 16th legislature – National Assembly (assemblee-nationale.fr)
September 29, 2023: UK
On September 27, 2023, the UK government amended the draft legislation to be included in the 2024 Finance Bill (‘2024 Draft Finance Bill’) to (1) domestically implement amendments provided in the July 2023 OECD Administrative Guidance, (2) include some ancillary amendments from the February 2023 OECD Administrative Guidance and (3) provide for other related changes.
UK Amends 2024 Draft Finance Bill For OECD Administrative Guidance » (oecdpillars.com)
September 27, 2023: Bulgaria
Yesterday, the Bulgarian Ministry of Finance issued a draft law to implement the EU Global Minimum Tax Directive. This includes an IIR and QDMTT from January 1, 2024 and a UTPR from January 1, 2025.
The draft law is open for consultation until October 26, 2023.
Ministry of Finance :: Drafts of normative and other acts (minfin.bg)
A Review of Bulgaria’s Draft Pillar Two Law » (oecdpillars.com)
September 25, 2023: Hungary
It has been reported that the Hungarian draft legislation to implement the EU Global Minimum Tax Directive is to be included in the Autumn 2023 tax package that will be presented to Parliament at the beginning of October 2023.
Mihály Varga initiates important tax negotiations, new rules could come in October – Portfolio.hu
September 21, 2023: Turkey
On September 19, 2023, Turkey gazetted the amendments to IAS 12, as previously announced by the IASB.
The two key amendments to IAS 12 were:
– a temporary exception to accounting for deferred taxes arising from the implementation of the Pillar Two GloBE rules; and
– targeted disclosure requirements
An MNE will need to disclose separately its current tax expense related to Pillar Two income taxes beginning on or after 1 January 2023. In practice this will apply from 1 January 2024 when Pillar Two legislation is expected to be in effect in many jurisdictions.
Turkish Gazette (resmigazete.gov.tr)
https://oecdpillars.com/iasb-publishes-amendments-to-ias-12-for-the-globe-rules/
September 19, 2023: Argentina
It’s been reported that the national government will send a project to the National Congress to establish a 15% global minimum tax, based on the GloBE rules on Friday this week, as part of the 2024 Budget.
The UAE Ministry of Finance confirmed in its Pillar Two Regional Forum that the UAE will not be implementing the Pillar Two GloBE rules in 2024. There is to be a public consultation in Q1 of 2024.
September 5, 2023: France
Today, the French draft of the law to implement the EU Global Minimum Tax Directive is being reviewed by the Finance Section of the Council of State, for enactment by December 31, 2023. No text is yet publicly available.
September 4, 2023: Italy
On August 14, 2023, Law 111 was published in the Italian Official Gazette. Article 3.1.e requires the Government to implement the EU Global Minimum Tax Directive into Italian law. It also requires the government to introduce:
– a domestic top-up tax for in-scope Italian entities belonging to a multinational or domestic group; and
– a penalty regime, compliant with that in force for income tax, for violation of the obligations regarding minimum taxation of multinational and national groups including relevant information requirements.
The law is effective from August 29, 2023, and the Government has up to 24 months to implement the above via legislative decree.
This will allow the Government to implement the GloBE rules quickly as they will not need to go through the usual Parliamentary process. Legislative Decrees are permitted under Article 77 of the Italian constitution and are effectively delegated legislation whereby the Italian government can issue decrees that have the force of ordinary laws within the parameters set by Parliament.
August 30, 2023: Taiwan
Taiwan’s Ministry of Finance confirmed today there is no set schedule for the introduction of the Pillar 2 GloBE rules in Taiwan. It suggests:
– In the short-term, reviewing Taiwan’s tax system, providing moderate tax incentives to maintain the effective tax rate of MNEs at 15%, and reducing the compliance costs of MNE groups in Taiwan should be the top priority. The Ministry of Finance has previously suggested raising the rate of corporate income tax.
– In the medium term, in order to avoid other jurisdictions levying top-up tax on Taiwanese low-taxed entities, a QDMTT should be considered.
– In the long term, the introduction of the IIR/UTPR aspects of the GloBE rules will be evalutated, depending on international implementation status.
August 28, 2023: Czech Republic
On August 16, 2023, the Czech Cabinet approved the Draft Top-up Tax Act to give effect to the GloBE rules. The Draft law now requires Parliamentary approval.
This replaced the previous Draft Top-Up Tax Bill. The new proposed legislation is more comprehensive than the previous Bill and includes additional aspects of the OECD Administrative Guidance.
See our Czech Republic: GloBE Country Guide
August 24, 2023: Germany
On August 16, 2023, the Federal Cabinet adopted the government draft for the implementation of the Pillar Two GloBE Rules.
August 20, 2023: Australia
The Australian Taxation Office is undertaking a targeted consultation with in-scope MNEs and their advisors on the implementation of the OECD GloBE rules under Pillar Two in Australia, with a focus on potential administration issues. See:
Business | Australian Taxation Office (ato.gov.au)
August 16, 2023: Finland
On August 15, 2023, the Finnish Ministry of Finance issued a draft law for the implementation of the EU Global Minimum Tax Directive (the ‘EU Directive’). The draft law is subject to a consultation until September 8, 2023.
As provided in the EU Directive, the draft law includes an income inclusion rule (IIR) and an under-taxed profits rule (UTPR).
The draft law is planned to be effective from January 1, 2024, with the IIR applying to financial years beginning on after December 31, 2023. The UTPR will generally apply to financial years beginning on after December 31, 2023 (aside from where a jurisdiction opts for the delayed application of the GloBE rules under Article 50 of the EU Directive).
A domestic minimum tax (intended to be a Qualified Domestic Minimum Top-Up Tax (‘QDMTT’)) is also proposed to apply for financial years beginning on after December 31, 2023.
Key Aspects of Finland’s Draft GloBE Law » oecdpillars.com
August 11, 2023: Australia
Today the Australian Taxation Office confirmed the timeline for consultation on its introduction of the Pillar 2 GloBE rules.
They have commenced targeted public consultation with selected taxpayers likely to be in scope of Pillar 2 with a focus on potential administration issues. Consultation is being undertaken in a phased approach:
Phase 1 with industry groups and their members (July – August 2023)
Phase 2 with mid-tier firms (August – October 2023)
Phase 3 with large advisory firms (September – November 2023)
It was confirmed that the consultation will not cover matters of tax policy.
August 11, 2023: Vietnam
On August 2, 2023, the Vietnamese government issued Draft Resolution No. 122/NQ-CP, the 2023 on the introduction of the GloBE rules in Vietnam.
It does not yet include the draft legislation but outlines the government’s commitment to introducing Pillar 2,
The Draft Resolution provides that Vietnam will implement both the IIR and a QDMTT from 1 January 2024.
Given the short time period to get these introduced, the government plans to issue regulations to provide for the detailed rules. These will then be replaced with amendments to the Corporate Income Tax at some point.
August 10, 2023: Switzerland
On August 8, 2023 the Swiss Federal Department of Finance released a first report on the effects of the implementation of the OECD minimum tax on the individual cantons.
Based on the outcome provided by the report:
– Some cantons (Appenzell Innerrhoden, Bern, Glarus, Jura, Obwalden, Wallis, Zurich) have no plans for adjustments to corporate taxation).
– In the cantons of Basel-Stadt, Schaffausen, Solothurn it is unclear what changes will be made.
– Other cantons (Aargau, Appenzell Ausserrhoden, Basel-Landschaft, Geneve, Luzern, Neuchatel) have already passed new legislative measures or issued drafts for discussion.
First report on cantonal measures relating to the implementation of the OECD minimum tax (admin.ch)
August 9, 2023: Luxembourg
On 4 August 2023, the Luxembourg government issued Draft Law No. 8292 to implement the EU Minimum Tax Directive.
Key Aspects of the Luxembourg Draft GloBE Law » oecdpillars.com
August 9, 2023: Bermuda
On August 8, 2023, the Government of Bermuda issued a Public Consultation on the Introduction of Corporate Income Tax in Bermuda for tax years beginning on or after January 1, 2025. See:
Bermuda Issues Consultation for a Corporate Income Tax » oecdpillars.com
August 7, 2023: Canada
On August 4, 2023, Canada issued the draft Global Minimum Tax Act for consultation. The consultation closes on September 8, 2023.
The draft legislation includes an income inclusion rule (IIR) and a domestic minimum tax (intended to be a Qualified Domestic Minimum Top-Up Tax (QDMTT), for fiscal years beginning on or after December 31, 2023.
Whilst the legislation is comprehensive it does not exactly mirror the Model GloBE rules and all issued OECD guidance.
Whilst the first Administrative Guidance is reflected in the draft legislation, few aspects of the second set of Administrative Guidance (issued in July 2023) are included.
For instance, there are no rules governing Transferable Tax Credits and there is no UTPR Safe Harbour.
The domestic minimum tax is based on the top-up tax calculation for GloBE purposes, as amended. The amendments include not allocating tax to PEs, CFCs and Hybrids. The draft law also excludes tax on the owner of a constituent entity (CE) on dividends paid by the CE. However, this goes further than the OECD Administrative Guidance which allows withholding tax to be pushed down.
The Second set of OECD Administrative Guidance also provides that where not all Constituent Entities in the jurisdiction use the local currency as their functional currency, the Filing Constituent Entity may make a Five-Year Election to undertake the QDMTT computations for all Constituent Entities in the jurisdiction either:
– in the presentation currency of the Consolidated Financial Statements; or
– in the local currency.
This is not included in the Canadian domestic minimum tax.
It should also be noted that the definition of an acceptable accounting standard excludes Russia (unlike the OECD Model Rules).
ita-lir-0823-l-4-eng.pdf (canada.ca)
August 4, 2023: Slovakia
On August 3, 2023, the Slovakian Ministry of Finance issued draft legislation for the implementation of the EU Global Minimum Tax Directive. This is subject to an interdepartmental comment procedure until until August 23, 2023.
– The Transitional CbCR Safe Harbour
– The UTPR Safe Harbour
– The QDMTT
Providing that relevant provisions should be construed to ensure, as far as practicable, consistency between it and the OECD Model Rules and guidance.
A General Elections Section covering the application of one and five-year elections is also included.
The QDMTT Safe Harbour is under construction and is not included in the Second Feedback Statement.
It also seeks feedback on
– proposed penalty provisions
– the allocation of top-up tax on a CE-by-CE basis under the QDMTT, in light of the transitional simplified jurisdictional reporting framework
July 31, 2023: South Korea
On July 28, 2023, the South Korean government published the Partial Amendment Proposal for the International Tax Adjustment Act, to amend their Pillar Two law to (1) take account of a number of OECD amendments issued in their Administrative Guidance, and (2) delay the implementation of the UTPR until January 1, 2025.
This includes:
– Excluding the government from the application of the global minimum tax (Article 61(1)(1)(a))
– Companies with only stateless permanent establishments are excluded from the MNE group (Article 61(1)(2)(b)
– Clarification of the definition of permanent establishment (Article 61(1)(3)(a) and (b))
– Regulations for the special rules for investment constituent companies (draft Article 61(1)(18)
– Excess negative tax expense carry-forwards (Article 69(4))
– Taxable distribution method election Article 73(5) and (7)
– Regulation of the transition period for the CbCR Safe Harbour (Article 80)
– Transitional Penalty Relief (Article 84, Paragraph 5 and Article 87, Paragraph 4)
July 28, 2023: Luxembourg
On 28 July 2023, the Government approved the draft law aimed at transposing the EU Minimum Tax Directive into Luxembourg law. The Bill will be submitted to the Chamber of Deputies in the next few days.
July 19, 2023: UK
On July 18, 2023, the UK issued draft legislation for the introduction of the UTPR. It will commence as appointed by the Treasury in regulations, which will not be before accounting periods beginning before December 31, 2024. See: Review of the UK Draft UTPR Law
July 19, 2023: Gibraltar
In the 2023 Budget Speech, Gibraltar announced it is to introduce the Pillar 2 GloBE rules and a domestic minimum tax which will take effect no earlier than accounting periods beginning on or after 31 December 2024.
CM BUDGET SPEECH 2023.pdf (gibraltar.gov.gi)
July 17, 2023: OECD
Today, the OECD issued the model provision for the Subject-to-tax Rule (STTR) and its commentary. Included in the guidance are specific provisions in Chapter II governing the application of elimination of double taxation provisions in respect of additional tax payable under the STTR.
We will prepare a detailed analysis over the next few days.
Additionally the following was also released:
– The GloBE Information Return Model: and
– Additional Administrative Guidance (including guidance on the SBIE, tax credits, currency conversions, the QDMTT safe harbour and a UTPR safe harbour for fiscal years commencing on or before the end of 2025):
A Review of the OECDs Second Set of GloBE Administrative Guidance » (oecdpillars.com)
Key Aspects of the GloBE Information Return Guidance
July 13, 2023: UK
The Finance (No. 2) Act, 2023 received Royal Assent on July 11, 2023. As such the UK legislation to give effect to the Pillar Two GloBE rules is now enacted.
See:
UK Enacts New Multinational Top-Up Tax From December 31, 2023
July 12, 2023, OECD
Yesterday, the OECD issued an Outcome Statement on Pillars 1 & 2 that gives an update on the status and timeline for implementation of Amount A and B of Pillar One, and the Subject-to-Tax Rule (STTR).
Amount A
A Multilateral Convention (MLC) for the implementation of Amount A of Pillar One has been developed. It will be published for signature in the second half of 2023, with a signing ceremony organised by year-end. The MLC should enter into force during 2025, allowing for the domestic consultation, legislative, and administrative processes applicable in each jurisdiction.
Amount B
Further work on Amount B of Pillar One is to be launched next week with a public consultation until 1 September. This is aimed to be completed for year-end. The Inclusive Framework plans to approve a final report on Amount B and incorporate key content into the OECD Transfer Pricing Guidelines by January 2024.
Subject-to-Tax Rule (STTR)
The STTR model provision and commentary is to be published next week, with the Multilateral Instrument implementing the STTR to be released and open for signature from 2 October 2023.
Digital Service Taxes
138 countries and jurisdictions have also agreed in the Outcome Statement to not impose any new DSTs (or relevant similar measures) on any company before 31 December 2024, or the entry into force of the MLC if earlier, provided the signature of the MLC has made sufficient progress by the end of the year.
July 11, 2023,: Germany
On July 10, 2023, Germany issued a Draft Bill for the implementation of the GloBE Rules. This follows a previous discussion draft:
July 10, 2023: UK
The Finance (No. 2) Bill, 2023, (which includes legislation to enact the new multinational top-up tax) has been passed by both the House of Commons and the House of Lords. Royal Assent (which is required to enact the law) is scheduled for tomorrow:
Finance (No. 2) Bill Stages – Parliamentary Bills – UK Parliament
July 3, 2023: Japan
On June 30, 2023, the Ministry of Finance issued a Ministerial Ordinance to Partially Amend the Enforcement Regulations of the Corporation Tax Act.
This provides further details for the implementation of the GloBE rules from April 1, 2024.
Overview of Japan’s Latest Ministerial Ordinance on Pillar 2
Internet Official Gazette (npb.go.jp)
Corporate Tax Law Enforcement Regulations | e-Gov Law Search
We will prepare an analysis of the new Ministerial Ordinance.
June 28, 2023: Israel
Local media reports state that Israel’s Finance Minister has reaffirmed Israel’s commitment to adopting the Pillar Two rules.
A working group comprised of the Tax Authority and the Chief Economist’s Division and the Budget Division of the State Revenue Administration is examining the implications of implementing the OECD Model GloBE Rules for Israel. They are expected to submit their recommendations to the finance minister shortly.
In Israel, various multinational companies (including Intel) enjoy particularly low tax rates, which can reach 6% under capital investment encouragement laws.
The Ministry of Finance is promoting: corporate tax of at least 15% – Globes
June 27, 2023: Denmark
On June 23, 2023, the Danish Ministry of Taxation issued the draft Minimum Tax Act (the ‘Bill’) to give effect to the GloBE rules.
See: A Review of the Danish Draft Minimum Tax Act
June 19, 2023: Switzerland
The Swiss referendum on June 18, 2023 approved the introduction of a global minimum tax from January 1, 2024.
Given the public approval, Switzerland will implement the Pillar Two GloBE rules via a temporary decree of the Federal Council.
A second consultation of a draft Pillar two Decree has been launched. This is subject to a consultation until September 14, 2023. Both Decrees will then be merged, taking into account the results of the consultation and any further technical requirements of the OECD.
OECD minimum taxation (admin.ch)
June 16, 2023: Japan
On June 16, 2023, a Cabinet Order to Partially Amend the Enforcement Order of the Corporation Tax Law was published in the Official Gazette:
Internet Official Gazette (npb.go.jp)
The “Act for the Partial Revision of the Income Tax Act” was promulgated in Special Issue No. 25 of the Official Gazette on Friday, March 31, 2023 as Act No. 3/2023.
Whilst this Act implements the global minimum tax in Japan from April 2024, it left a number of the crucial details outstanding as they were to be included in future Cabinet Orders.
Therefore, the calculation of GloBE income (Article 82 of the Bill) and Adjusted Covered Taxes were to be stipulated by Cabinet Order. This new Cabinet Order provides more granular detail on the operation of the Global Minimum Tax in Japan.
See: Overview of Japan’s Cabinet Order on the Global Minimum Tax
June 15, 2023: UK
The UK government issued draft guidance on the application of the UK IIR and QDMTT that was included in the Spring 2023 Finance Bill.
The guidance provides additional information on which groups will be in scope, and on how the taxes will be administered and charged. It us subject to a consultation until September 12, 2023.
UK Issues First Tranche of Draft Guidance on Global Minimum Tax
Draft guidance: multinational top-up tax and domestic top-up tax – GOV.UK (www.gov.uk)
June 7, 2023: Norway
Yesterday, the Norwegian Ministry of Finance launched a consultation (including draft legislation) on the implementation of the Pillar Two GloBE Rules in Norway.
Norway Issues Consultation and Draft Law For Pillar 2 Rules
June 6, 2023: Kuwait
In Section 8 of yesterdays Concluding Statement of the IMF 2023 Article IV Mission to Kuwait, the IMF recommended that the 15 percent corporate income tax should be expanded to cover domestic firms, which would bring Kuwait into conformity with the OECD global minimum corporate tax for multinationals.
Currently under Kuwait Decree No. 3/1955, as amended by Kuwait Law No. 2/2008, the 15% corporate income tax only applies to foreign entities carrying on a trade or business in Kuwait, except entities registered in GCC countries (Kuwait, Saudi Arabia, Bahrain, United Arab Emirates, Oman and Qatar and wholly owned by Kuwaiti /GCC citizens).
This would therefore mean that domestic entities within the scope of Pillar Two could be subject to top-up tax in a foreign UPE/IPE/POPE/Group Entity (depending on the nature and location of group ownership) unless Kuwait implemented a domestic CIT regime (ideally a QDMTT to eliminate any foreign top-up tax).
Kuwait: Staff Concluding Statement of the 2023 Article IV Mission (imf.org)
June 1, 2023: The Netherlands
The Netherlands presented the Minimum Tax Bill, 2024 to Parliament yesterday. It implements an Income Inclusion Rule and a Domestic Minimum Tax (intended to be a Qualified Domestic Minimum Top-Up Tax) for financial years commencing on or after December 31, 2023. An Under-Taxed Profits Rule applies for financial years commencing on or after December 31, 2024.
The Netherlands Sends GloBE Minimum Tax Act to Parliament » (oecdpillars.com)
June 1, 2023: IASB
Today, the International Accounting Standards Board (IASB) proposed amendments to the IFRS for SMEs Accounting Standard to help small- and medium-sized entities (SMEs) respond to Pillar Two.
May 30, 2023: IASB
The IASB announced it expects to publish an Exposure Draft for proposed amendments to Section 29 Income Tax of the IFRS for SMEs Accounting Standard (to take account account of the Pillar Two Model Rules) on June 1, 2023.
IFRS – IASB to propose urgent amendments to the IFRS for SMEs Standard for OECD tax reform
May 29, 2023: Hungary
Media reports in Hungary suggest that the domestic legislation to implement the Pillar Two GloBE rules will be submitted to Parliament shortly.
May 29, 2023: Vietnam
Although corporate income tax is currently at 20%, Vietnam applies a number of tax incentives which means that the average income tax rate on multinational corporations is currently approximately 12.3 per cent.
Incentives include: tax rate incentives (10% up to 15 years and 20% up to 10 years), limited-term tax exemptions and reductions (up to 9 years), allowable loss transfers (within 5 years), exemption from taxation of remittance of profits abroad, tax refunds for reinvested profits, accelerated depreciation. In special economic zones, preferential mechanisms may be even more long-term.
The two key amendments are:
– a temporary exception to accounting for deferred taxes arising from the implementation of the Pillar Two GloBE rules; and
– targeted disclosure requirements
See:
IFRS – IASB amends tax accounting requirements to help companies respond to international tax reform
See our review of the draft IASB proposals at:
IASB Issues Staff Papers on Updated Pillar 2 Tax Accounting Proposals
May 19, 2023: Guernsey, Jersey and the Isle of Man
The governments of Guernsey, Jersey and the Isle of Man (‘the Islands’) announce that they have reached a decision on a joint approach to the OECD’s Pillar Two framework. They plan to implement an Income Inclusion Rule and a domestic minimum tax from 2025.
Crown Dependencies announce agreed approach to Pillar Two Framework (gov.je)
May 19, 2023: IASB
The International Accounting Standards Board expects to issue International Tax Reform—Pillar Two Model Rules, which amends IAS 12 Income Taxes, on 23 May 2023:
IFRS – IASB to issue International Tax Reform—Pillar Two Model Rules
May 19, 2023: Czech Republic
A spokesperson for the Ministry of Finance confirmed that the GloBE Law is currently in the external comment procedure and (as provided in the EU Global Minimum Tax Directive) is proposed to be implemented from January 1, 2024.
The draft law can be viewed at:
https://odok.cz/portal/services/download/attachment/KORNCRUFF5QG/
See: A Review of the Czech Draft Top-Up Tax Act
May 18, 2023: New Zealand
On May 18, 2023, New Zealand published a draft law (the Taxation (Annual Rates for 2023–24, Multinational Tax, and Remedial Matters) Bill) to implement the Pillar Two Global Minimum Tax. See:
New Zealand Issues Draft Global Minimum Tax Law
May 17, 2023: G7
On May 13, 2023, the G7 finance ministers reaffirmed their commitment to both Pillars One and Two.
They stated:
‘…We re-emphasize our strong political commitment towards the swift global implementation of the OECD/G20 Inclusive Framework Two-Pillar Solution to address the tax challenges arising from globalization and the digitalization of the economy and to establish a more stable and fairer international tax system. We recognize significant progress in the negotiation of the Pillar 1 Multilateral Convention (MLC) and reaffirm our commitment to the swift completion of the negotiation so that the MLC can be ready for signature within the agreed
timeline.
We welcome the progresses in domestic legislation toward the implementation of Pillar 2 and call upon the Inclusive Framework to work on further administrative guidance for a globally consistent implementation. We will further provide developing countries with support for strengthening their tax capacity to build sustainable tax revenue sources, highlighting the importance of assistance for the implementation of the Two-Pillar Solution. We welcome the OECD’s “2023 Progress Report on Tax Co-operation for the 21st Century…’.
May 9, 2023: Australia
In todays’ Budget speech, the Government confirmed it will introduce :
– A 15 per cent global minimum tax for large multinational enterprises with the Income Inclusion Rule applying to income years starting on or after 1 January 2024 and the Undertaxed Profits Rule applying to income years starting on or after 1 January 2025.
– A 15 per cent domestic minimum tax applying to income years starting on or after 1 January 2024.
See: Australian Budget Confirms 2024 GloBE Implementation
April 25, 2023: Switzerland
Yesterday, the Swiss Federal Council and Parliament issued a Press Conference in which they recommended that voters accept the constitutional amendment to implement the global minimum tax in the vote taking place on 18 June 2023.
April 24, 2023: Germany
On April 14,2023, the German Federal Ministry of Justice published a document containing a number of proposals to reduce bureaucracy for German companies. The measures could be implemented via direct legal measures by relevant ministries or in another Bureaucracy Relief Act.
The document provides that the planned transitional provisions for the recognition of CbCR data as a basis for a safe harbour must be converted into a permanent regulation.
In addition, it proposes that countries on a “white list” (such as the US) whose nominal tax rate is sufficiently above the 15% global minimum rate should be exempted from the Pillar Two reporting requirement.
April 19, 2023: Japan
On April 17, 2023, the Japanese National Tax Agency published a high level overview of the recently enacted Law No. 3/2023 to implement a Global Minimum Tax. See:
Global Minimum Taxation|National Tax Agency (nta.go.jp)
April 17, 2023: UK
The UK proposed some minor technical changes to the domestic implementation of the Pillar Two GloBE rules on April 14, 2023.
The changes relate to the calculation of adjusted covered taxes and the transitional rules. They are designed to avoid any unintended outcomes from the application of the rules.
For instance, Amendment 12 includes an amendment to Section 174 of the Finance Bill.
Section 174 includes a number of steps to calculate adjusted covered taxes.
Step 4 provides for an adjustment to reflect any amounts allocated to other group members or from other group members. This includes permanent establishments, hybrid entities, transparent entities, reverse hybrid entities, controlled foreign companies and taxes on distributions.
However, these amounts are already adjusted for, as Article 174 excludes any amount allocated to another member of the multinational group and Article 175 includes amounts allocated to the member from another member of the multinational group.
As such, amendment 12 removes this Step.
April 14, 2023: Nigeria
Yesterday, the OECD and Nigeria’s Federal Inland Revenue Service issued an Outcome Statement from a two day workshop held to discuss the two-pillar solution.
See: Nigeria Reconsidering Its Approach To Pillar Two
April 12, 2023: IASB
Yesterday, the IASB approved the updated proposals in the IASB Staff Papers, to provide for:
– a temporary exception to accounting for deferred taxes arising from the implementation of the Pillar Two model rules; and
– targeted disclosure requirements
The disclosure requirements in particular have changed from the original exposure draft.
April 11, 2023: Vietnam
Local reports state that the Ministry of Finance is collecting feedback on its proposals to develop the Global Minimum Tax Law and will submit it to the Government in June 2023, and aims to submit it to the National Assembly at its 6th Session in October 2023.
Dự luật thuế tối thiểu toàn cầu: Chính phủ chưa trình, Quốc hội yêu cầu bổ sung (quochoitv.vn)
April 7, 2023: IASB
The IASB released five Staff Papers providing an update to tax accounting under IFRS for Pillar Two. The IASB had previously issued an Exposure Draft for proposed amendments to IAS 12 to take account of the Pillar Two Model Rules.
See: IASB Issues Staff Papers on Updated Pillar 2 Tax Accounting Proposals
April 6, 2023: Czech Republic
The Ministry of Finance plans to publish the Pillar Two GloBE bill in mid-May 2023.
Confederation of Industry organized a seminar on the global minimum tax (spcr.cz)
April 5, 2023: United Kingdom
The FRC has today issued FRED 83 Draft amendments to FRS 102 The Financial Reporting Standard applicable in the UK and Republic of Ireland – International tax reform – Pillar Two model rules, which proposes to introduce a temporary exception to the accounting for deferred taxes arising from the implementation of the OECD’s Pillar Two model rules, alongside targeted disclosure requirements.
FRED 83 is based on similar proposals issued by the IASB. To make similar accounting relief and disclosure requirements available in the FRC’s financial reporting standards to a consistent timeframe the FRC is consulting now, rather than waiting for the IASB’s final amendments.
Comments on FRED 83 are requested by May 24, 2023.
See A Review of FRED 83 – The UK’s Pillar 2 Tax Accounting Proposals.
April 4, 2023: Denmark
The Ministry of Taxation and the Ministry of Industry, Business and Financial Affairs have sent a questionnaire to Danish MNEs expected to be within the scope of the Pillar Two GloBE Rules.
The questionnaire asks a number of questions related to the preparation and reporting of GloBE Information Return.
The completed questionnaire is required to be submitted to the Danish Business Authority via email by April 12, 2023.
Questions include:
April 3, 2023: Ireland
On March 31, 2023, the Irish government issued a Feedback Statement on the Pillar Two Global Minimum Tax.
It includes draft legislation and outlines possible draft legislative approaches to key elements of the GloBE Rules. It is open for comments until May 8, 2023.
See: Ireland Issues Draft Global Minimum Tax Law For Feedback
March 31, 2023: Japan
Today, the Accounting Standards Board of Japan (ASBJ) issued the Practical Response Report on the ‘Treatment of Deferred Tax in Relation to the Revision of the Corporation Tax Act Corresponding to Global Minimum Taxation’
Unlike the IASB, the ASBJ is not requiring specific disclosure requirements, however it does provide a short-term exception to accounting for deferred tax arising from the global minimum tax.
The Practical Response Report is applicable from today and until it is repealed by the ASBJ.
March 31, 2023: Kenya
It’s been reported that Kenya is to sign up to the Two Pillar Solution.
It was not a signatory to the original October 2021 Statement as it was not prepared to remove its digital service tax as required for Pillar One. The Income Tax (Digital Service Tax) Regulations, 2020, provide for a 1.5% digital services tax.
It’s now reported that Kenya is prepared to implement the OECD agreement and will remove its DST if/when Pillar One is implemented.
March 31, 2023: Japan
Japan gazetted its Global Minimum Tax law today.
The “Act for the Partial Revision of the Income Tax Act” was promulgated in Special Issue No. 25 of the Official Gazette on Friday, March 31, as Act No. 3/2023.
March 30, 2023
On March 29, 2023, Liechtenstein published draft legislation for the implementation of the Pillar Two Globe Rules.
See: Liechtenstein Publishes Draft Global Minimum Tax Law
March 29, 2023: Japan
On March 28, 2023, Japan enacted a domestic law to give effect to the Pillar Two GloBE rules from April 1, 2024.
See: Japan’s Global Minimum Tax Law Is Enacted
March 29, 2023: Canada
In yesterday’s 2023 Canadian Budget, the government confirmed that it will introduce legislation implementing the Income Inclusion Rule (IIR) and a domestic minimum top-up tax (QDMTT) applicable to Canadian entities of MNEs with effect for fiscal years of MNEs that begin on or after December 31, 2023.
The government also intends to implement the UTPR with effect for fiscal years of MNEs that begin on or after December 31, 2024.
The government intends to release draft legislative proposals for the IIR and domestic minimum top-up tax for public consultation in the coming months, with draft legislative proposals for the UTPR to follow at a later time.
March 24, 2023: UK
The Spring Finance Bill 2023 (Finance (No. 2) Bill) was published yesterday (March 23, 2023), along with its Explanatory Notes. The Bill includes provisions to implement key aspects of the Pillar Two Global Minimum Tax for accounting periods beginning on or after 31 December 2023.
See: Review of the UK Global Minimum Tax in Yesterday’s 2023 Spring Finance Bill
March 21, 2023: Germany
On March 20, 2023, the German Federal Ministry of Finance published a consultation, including a draft law (the Minimum Taxation Directive Implementation Act), to implement the EU Global Minimum Tax Directive. The consultation is open for comments until April 21, 2023.
See: Germany Publishes Draft Global Minimum Tax Legislation
March 20, 2023: Barbados
In the 2023 Budget on March 14, 2023, the Prime Minister of Barbados confirmed that the Barbados Revenue Authority has already started consultations with impacted entities with a view to implementation of the GloBE rules.
On page 90 of the 2023 Budget Speech, the Prime Minister Stated:
“…Mr. Speaker, you have not heard me address the Global Minimum Corporate Tax. Not because we are not ready or started the consultations, but we are deep in them with the Barbados Revenue Authority speaking to the entities that are located here and there is still much evolving on both sides of the Atlantic and I anticipate we will come back to the country within six months on this issue…”
With a domestic corporate income tax rate of 5.5% (Section 43 of the Income Tax Act (as amended)), Barbadian resident companies suffer corporate income tax at a rate significantly below the 15% globally agreed minimum rate. The response to Pillar Two is therefore of particular interest to the global tax community.
Given there will be consultations on the Pillar Two GloBE rules with MNEs over the next few months before any firm proposals are expected, it may be unlikely that the rules will be in place for 2024. Barbados may look to emulate Singapore, Hong Kong and Thailand and opt for a 2025 implementation.
March 15, 2023: United Kingdom
In today’s 2023 Spring Budget, the UK government confirmed that it will include the Pillar Two Global Minimum Tax in the Spring Finance Bill 2023.
In particular, for accounting periods beginning on or after December 31, 2023, the UK will apply a multinational top-up tax, and a qualified domestic minimum top-up tax.
UK Confirms 2024 Global Minimum Tax & QDMTT in 2023 Spring Budget
March 15, 2023: Vietnam
Last week, the Vietnamese Government released Resolution 31/NQ-CP of the February 2023, Regular Government Session. It requires the Ministry of Finance to assume the prime responsibility for, and coordinate with, the Ministry of Planning and Investment and other relevant agencies to urgently complete the study and report on the global minimum tax mechanism. The final report is to be sent to the Prime Minister in March 2023.
March 10, 2023: Hungary
Yesterday, Hungary’s Prime Minister Viktor Orbán reiterated that Hungary has an Official letter from the EU agreeing to the Local Business Tax being a covered tax for the purposes of the Pillar Two Global Minimum Tax.
See: Hungary’s Prime Minister Reiterates the Local Business Tax is a Covered Tax for GloBE Purposes
March 9, 2023: Spain
On March 6, 2023, Spain’s Ministry of Finance and Public Function opened a public consultation on the transposition into Spanish law of the European Directive on the Global Minimum Tax (Council Directive (EU) 2022/2523 of 14 December 2022).
See: Spain Opens a Consultation on the Global Minimum Tax
March 8, 2023: Thailand
Yesterday, the Thai Cabinet approved the proposal to implement a Global Minimum Tax (see item 48 of the following Cabinet Resolution:
รัฐบาลไทย-ข่าวทำเนียบรัฐบาล-สรุปข่าวการประชุมคณะรัฐมนตรี วันที่ 7 มีนาคม 2566 (thaigov.go.th)
The next step is for draft legislation to be prepared and released. The above Cabinet Summary notes that the Revenue Department is currently in the process of preparing a top-up tax collection law.
Whilst the bill is expected to be released this year, importantly Thailand is proposing that the provisions of the Global Minimum Tax apply from 2025. This is the same time frame as both Singapore and Hong Kong. It is expected that Thailand will also include a QDMTT.
March 7, 2023: Brazil
Yesterday, Grace Perez Navarro, the Director of the OECD’s Centre for Tax Policy and Administration, recommended to Brazil’s Finance Minister (Fernando Haddad) that the implementation of the 15% global minimum tax on multinational companies should be part of Brazil’s tax reform package.
See: OECD Recommends Global Minimum Tax is Included in Brazil’s Tax Reform
March 2, 2023: Belgium
On March 2, 2023, the Belgian Minister of Finance announced the first phase of a broad tax reform that will include the Pillar Two global minimum tax.
The document outlining the proposals provides that Belgium will introduce a global minimum tax in line with the OECD Pillar Two framework from January 1, 2024.
This ties in with EU Council Directive (EU) 2022/2523 of 14 December 2022. That requires EU member states to enact laws, regulations and administrative provisions necessary to comply with the EU Pillar Two Directive by 31 December 2023.
As such, the Income Inclusion Rule will need to be implemented in Belgium (and other EU states) for fiscal years beginning from December 31, 2023 and the Under-Taxed Payments Rule will apply for fiscal years beginning from 31 December 2024.
February 28, 2023: Vietnam
On February 28, 2023, the Chairman of the Vietnamese National Assembly confirmed that the Vietnamese government is progressing in its proposals for the implementation of the Pillar Two Global Minimum Tax, including draft legislation to amend the Law on Corporate Income Tax.
See: Chairman of the Vietnamese National Assembly Confirms Pillar 2 Implementation Is Progressing
February 27, 2023: Bahamas
The Attorney General of the Bahamas, has stated that the government is planning to introduce a Pillar Two Global Minimum Tax.
Whilst this will only apply to MNEs within the scope of the GloBE Rules (ie MNE Groups that have annual revenue of 750 million euros or more in the consolidated financial statements of the UPE), it represents a seismic shift in the Bahamas tax system.
See:
The Bahamas & Cayman Islands Approach To The Global Minimum tax
February 24, 2023: Malaysia
Today’s 2023 revised Budget Statement did not include any reference to the implementation of the Pillar Two GloBE rules or a QDMTT.
However, it was referred to in the Highlights of the 2023 Revised Budget. Item 1.4 states:
Introduce minimum effective tax levels at the global level through Pillar 2 BEPS Action Plan 1 Tax Challenges Arising from Digitalization and implementing Qualified Domestic Minimum Top Up Tax (QDMTT) from 2024.
See: Today’s Malaysian 2023 Revised Budget Stands by 2024 Global Minimum Tax
February 23, 2023: South Africa
In yesterdays 2023 Budget, the South African Treasury confirmed that during the 2023 legislative cycle, the government will publish a draft position on the implementation of the Pillar Two global minimum tax for public comment and draft legislation will be prepared for inclusion in the 2024 Taxation Laws Amendment Bill.
See: South Africa Confirms Global Minimum Tax In 2024 Taxation Laws Amendment Bill
February 22, 2023: Hong Kong
In the 2023 Budget, Hong Kong’s Financial Secretary confirmed that Hong Kong will implement the Pillar Two Global Minimum Tax from 2025.
They estimate that it will generate tax revenue of $15 billion per year for the Government. A consultation is to be launched to allow MNE groups to make early preparation.
See: Hong Kong to Implement Global Minimum Tax in 2025
February 18, 2023: Bermuda
In Bermuda’s 2023 Budget, the government has announced it is actively looking at how to implement the Pillar Two global minimum tax and that Bermuda could reap significant revenue benefits.
See our article: Bermuda’s Plans For a Global Minimum Tax
February 17, 2023: China
The Accounting Standards Department of the Ministry of Finance issued Finance and Accounting Memorandum [2023] No. 1 to begin a consultation into the IASB Pillar Two Exposure Draft for proposed amendments to IAS 12 to take account of the Pillar Two Model Rules. The consultation ran from January 19, 2023, to February 17, 2023.
See our article: Chinese Developments in Global Minimum Tax Implementation
February 16, 2023: Indonesia
The Director of International Taxation of the Directorate General of Taxes has confirmed Indonesia is planning to implement the Pillar Two GloBE Rules from 2024. This is unlike Singapore which has delayed the implementation until 2025.
Mr Lindner announced to the Finance Committee that the upcoming implementation of the global minimum taxation “with the minimum necessary compliance effort for companies” would be published in the Official Gazette.
February 9, 2023: Japan
On February 8, 2023, the Accounting Standards Board of Japan (ASBJ) issued Exposure Draft No. 8 of the Practical Response Report “Draft Handling of Tax Effect Accounting for the Amendment of the Corporate Tax Act Corresponding to Global Minimum Taxation (Draft).
Unlike the IASB, the ASBJ is not proposing for specific disclosure requirements, however it is proposing a short-term exception to accounting for deferred tax arising from the global minimum tax. Comments are invited and a final Practical Response Report will then be issued.
February 7, 2023: Sweden
On February 7, 2023, the Special Investigator submitted the interim report on the proposal for the implementation of the Global Minimum Tax Directive to the government. This includes outline draft legislation which mainly corresponds to the EU directive but is adapted to Swedish conditions.
The Act is proposed to enter into force on 1 January 2024 and apply to tax years starting after 31 December 2023 (with the exception of the UTPR (known as the supplementary additional tax rule), which will apply after 31 December 2024). A QDMTT will also be implemented.
See:
Review of the Draft Swedish Global Minimum Tax Law
English Translation of the Swedish Draft Global Minimum Tax Law
February 6, 2023: Japan
January 25, 2023: Paraguay
The Deputy Minister of the Under Secretariat of State for Taxation (SET), Óscar Orué, participated in a regional seminar with a view to discussing and exploring the scope of the Global Minimum Tax.
January 4, 2023: Africa
African countries are discussing implementing a domestic minimum tax instead of unwinding existing tax incentives or applying cross-border minimum tax rules, an African Tax Administration Forum adviser has said.
See our article: ATAF Releases Draft Domestic Minimum Tax Legislation
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