Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in North Macedonia for accounting periods beginning on or after January 1, 2024. Updated for the legislation enacted on January 3, 2025
On December 31, 2024, Law No. 20612, was published to amend the International Tax Adjustment Act for the 2025 Tax Reform provisions. This includes some amendments to the Global Minimum Tax provisions.
On December 31, 2024, Ministerial Decree of December 27, 2024 was published in the Official Gazette. This implements Article 4.1-4.3 of the February 2023 OECD Administrative Guidance and some aspects of the June 2024 OECD Administrative Guidance on deferred taxation.
The Ministerial Decree of December 27, 2024 published in the Official Gazette on December 31, 2024 provides for a number of miscellaneous, but important aspects of the OECD Administrative Guidance that were not included in the original Minimum Tax Law.
The Dutch Minimum Tax Executive Decree 2024 was published in the Government Gazette on December 23, 2024 to implement various aspects of the OECD Administrative Guidance.
On December 26, 2024, The Emergency Decree on Top-Up Tax B.E. 2567, was published in the Government Gazette to implement the Pillar 2 GloBE rules from January 1, 2025.
On December 27, 2024, the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024 was published in the Official Gazette. The Bill includes an Income Inclusion Rule (IIR) and a domestic minimum tax from January 1, 2025.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Hong Kong for accounting periods beginning on or after January 1, 2025. Updated for the draft legislation issued on December 31, 2024.
On December 31, 2024, Oman issued Royal Decree No. 70/2024 to implement the Pillar 2 Income Inclusion Rule and a Domestic Minimum Tax from January 1, 2025..
On December 20, 2024, Curacao’s Global Minimum Tax Ordinancewas approved by Parliament and it was subsequently published on December 27, 2024.
On December 20, 2024, Curacao’s Global Minimum Tax Ordinance was approved by Parliament and it was subsequently published on December 27, 2024.
On December 30, 2024, Singapore published the Multinational Enterprise (Minimum Tax) Regulations 2024 which provide for the detailed rules for the application of the multinational top-up tax and domestic top-up tax.
On December 30, 2024, Brazil’s President enacted Law No. 15,079, of December 27, 2024 that repeats (with minor amendments) Provisional Measure No. 1,262, of October 3, 2024, to introduce a Domestic Minimum Tax (DMT) from January 1, 2025.
On December 30, 2024, Kuwait published Decree-Law 157 of 2024 for the introduction of a Domestic Minimum Top-Up Tax (DMTT) for in-scope MNE groups from January 1, 2025.
On December 21, 2024, Spain published Law 7/2024 in its Official Gazette to transpose the EU Minimum Tax Directive into domestic law.
On December 24, 2024, South Africa published the Global Minimum Tax Act in its Official Gazette. This applies an IIR and QDMTT from January 1, 2024.
On December 23, 2024, Australia issued the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024 to provide for the detailed application of the Pillar 2 GloBE rules in Australia.
On December 19, 2024, Luxembourg’s Parliament approved a law to amend its Global Minimum Tax Law to implement aspects of the OECD Administrative Guidance.
The Isle of Man has issued a domestic top up tax cessation form for entities that are located in the Isle of Man that are intending to enter liquidation, dissolution or any other form of winding up, or otherwise cease to be located in the Isle of Man for DTUT purposes
On December 13, 2024, the Tax Laws (Amendment) Act, 2024 was published in the Official Gazette. It comes into force on December 27, 2024 and includes a domestic minimum top-up tax.
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