Review of the Pillar 2 Provisions in the UK Finance Bill 2024-2025
On November 7, 2024, the Finance Bill 2024-2025 was introduced to Parliament. This includes provisions to enact the UTPR (and associated rules such as the Transitional UTPR Safe Harbour and Initial Phase of International Activity Exemption), and other Pillar 2 amendments.
Luxembourg GloBE Guide Updated for October 2024 Amendments to Draft Law
On October 31, 2024 additional amendments were made to the 2024 draft amendment law to incorporate aspects of the OECD June 2024 Administrative Guidance.
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.
