Singapore Issues Final Regulations for the Application of the Global Minimum Tax
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.
Brazil Enacts Domestic Minimum Tax Law and Issues Amended Regulations
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.
Kuwait Enacts its Domestic Minimum Top-Up Tax
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.
Spain Enacts its Global Minimum Tax Law
On December 21, 2024, Spain published Law 7/2024 in its Official Gazette to transpose the EU Minimum Tax Directive into domestic law.
South Africa Gazettes its Global Minimum Tax Act
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.
Australia Issues Rules for the Detailed Application of the Global Minimum Tax
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.
Luxembourg Parliament Approves Global Minimum Tax Amendment Law for OECD Administrative Guidance
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.
Isle of Man Issues the Cessation Form for Pillar 2 Domestic Top-Up Tax
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
Kenya Enacts a Domestic Minimum Tax in its Tax Laws (Amendment) Act, 2024
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.
The Netherlands Parliament Approves Law to Amend its Global Minimum Tax Law for OECD Administrative Guidance
On December 17, 2024, the Dutch Parliament approved a draft law to amend the GMT Law. This includes a number of amendments to implement further aspects of the February 2023 and July 2023 OECD Administrative Guidance and some aspects of the December 2023 OECD Administrative Guidance.
