Countries With Pillar 2 Provisions for Securitisation Entities
The Fourth Set of OECD Administrative Guidance (issued on June 17, 2024) includes guidance on the treatment of Securitization Entities.
A Review of Barbados’s Conditional Domestic Minimum Tax
On May 24, 2024, the Corporation Top-up Tax Act, 2024 was published in the Official Gazette. This implements a domestic minimum top-up tax intended to be a QDMTT for Pillar 2 purposes.
A Review of The Bahamas Pillar 2 Domestic Minimum Tax
On November 29, 2024, the Domestic Minimum Top-Up Tax Act, 2024 was published in the Official Gazette of The Bahamas. This implements a domestic minimum top-up tax intended to be a QDMTT for Pillar 2 purposes.
Finland’s Amendment Law and the Impact on its Global Minimum Tax Provisions
On December 19, 2024, Law 917/2024 was published in the Finnish Official Gazette to amend the Minimum Tax Act to reflect numerous aspects of the OECD Administrative Guidance. This applies to financial years beginning on or after January 1, 2024.
A Detailed Review of the Cyprus Global Minimum Tax Law
On December 18, 2024, Cyprus published the law to implement the EU Minimum Tax Directive its its Official Gazette. This implements the IIR from December 31, 2023 and a UTPR and domestic minimum tax from December 31, 2024.
Indonesia Publishes Regulation for IIR, UTPR and Domestic Minimum Tax
On December 31, 2024 the Indonesian Ministry of Finance issued Minister of Finance Regulation Number 136 of 2024 (the ‘Regulation’) for the imposition of a global minimum, tax which will take effect from January 1, 2025.
GloBE Country Guide: Indonesia
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Australia for accounting periods beginning on or after January 1, 2025. Updated for the Regulation issued by the Ministry of Finance on December 31, 2024.
A Review of the Australian Global Minimum Tax Rules
On December 23, 2024, Australia issued the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024 (the ‘Rules’) to provide for the detailed application of the Pillar 2 GloBE rules in Australia.
IIRs and DMTTs that don’t yet Qualify Under the OECD January 2025 Update
On January 15, 2025, the OECD issued Administrative Guidance that includes a list of jurisdictions that have transitional qualified status for the purposes of the income inclusion rule and domestic minimum tax (including the QDMTT Safe Harbour).
A Review of Changes in the OECDs Updated January 2025 GloBE Information Return
On January 15, 2025, the OECD issued an updated GloBE Information Return (GIR) and GIR XML Schema. In this article we look at the changes to the previous GIR.
