The Treatment of Permanent Establishments under Pillar Two
Permanent Establishments (PEs) are subject to a number of specific rules under Pillar Two in order to apply the general provisions to them. Key issues are what is a PE under Pillar Two? where is it located? and how are income and taxes allocated to it?
UK Issues a List of Jurisdictions that Have Qualified IIRs and DMTTs for Pillar 2
On March 21, 2025, the UK approved a list of jurisdictions that have qualified status for the purposes of the income inclusion rule and domestic minimum tax (including the QDMTT Safe Harbour).
GloBE Country Guide: Qatar
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Qatar for accounting periods beginning on or after January 1, 2025.
Qatar Enacts a Pillar Two Income Inclusion Rule and Domestic Minimum Tax
On March 27, 2025, Law No. 22 of 2024 was published in Qatar’s Official Gazette. This implements the Pillar Two Income Inclusion Rule and a Domestic Minimum Top- Up Tax from January 1, 2025.
Bulgaria Gazettes its 2025 Budget Law which Includes Numerous Changes to the Global Minimum Tax Regime
On March 27, 2025, Bulgaria’s 2025 State Budget Law (the ‘2025 Budget Law’) was published in the Official Gazette. This includes a number of changes to the Corporate Income Tax Law to amend the Global Minimum Tax provisions from January 1, 2024.
Insurance Investment Entities and Pillar Two
Insurance Investment Entities are subject to special treatment under the Pillar Two GloBE Rules. Read our analysis of the key provisions.
Italy Issues Decree for Double Filing Relief Notification Under the Pillar 2 Rules
On March 6, 2025 a Decree of the Italian Ministry of Finance on Notification Requirements for Global Minimum Tax purposes was published in the Official Gazette. This provides more details on the double filing relief notification under Article 51(4) of Legislative Decree December 27, 2023, no. 209 (the Global Minimum Tax Law).
The Treatment of Tax Transparent Entities Under Pillar Two
The Pillar Two Rules include specific provisions for tax transparent entities to avoid artificially low effective tax rates and significant top-up tax, particularly for tax transparent UPEs.
The Impact of Pillar 2 on Group HR/Payroll Companies
Centralized HR/payroll companies are frequently used by MNE groups but raise specific issues in relation to the Pillar Two GloBE Rules. In particular, the impact of using a centralized function and the nature of recharges could have an impact on the substance-based income exclusion of group entities.
Territorial Tax Systems and Pillar Two
Jurisdictions that apply a territorial basis do not tax foreign source income. This raises some interesting issues in the application of the Pillar 2 rules.
