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.
Italy Issues SBIE Decree to Implement the July 2023 and June 2024 OECD Administrative Guidance
On October 15, 2024, Italy issued Decree 11, of October 2024 on the calculation of the Substance-based Income Exclusion (SBIE) under Pillar 2. This includes all of the OECD Administrative Guidance on the SBIE.
Jersey GloBE Guide Updated for Final Enacted Law
On October 22, 2024, Jersey enacted the Multinational Taxation (Global Anti-Base Erosion – IIR Tax) (Jersey) Law 202 (the ‘IIR law’) and the Multinational Corporate Income Tax (Jersey) Law 202 (the ‘MCIT law’), to provide for the IIR and MCIT from January 1, 2025. Read our updated GloBE Country Guide.
Germany Releases its Group Parent Notification Form for German Minimum Tax Groups
On October 17, 2024, Germany released its Group Parent notification form for German minimum tax groups. Section 3 of the German GMT law provides that the Group Parent of the German minimum tax group is required to register with the Federal Tax Authority within 2 months of the end of the relevant fiscal period (ie February 28, 2025 for the 2024 fiscal year).
Jersey Enacts Law for the IIR and the MCIT
On October 22, 2024, Jersey enacted the Multinational Corporate Income Tax (Jersey) Law 202 and the Multinational Taxation (Global Anti-Base Erosion – IIR Tax) (Jersey) Law 202 to provide for the IIR and MCIT from January 1, 2025.
Lithuania GloBE Country Guide Updated for Latest Draft Law
On September 19, 2024, the Lithuanian government launched a public consultation on a draft law to fully implement the OECD’s Pillar Two Model Rules. Read our updated GloBE Country Guide.
France GloBE Country Guide Updated for the 2025 Finance Bill
On 10 October 2024, the French Government presented the draft Finance Bill for 2025 to Parliament. This includes amendments to its General Tax Code to reflect the OECD Administrative Guidance. Read our updated GloBE Country Guide.
Belgium Issues a Draft 7 Page QDMTT Return for Consultation
On October 18, 2024, Belgium issued a draft 7-page QDMTT Return for consultation. The consultation lasts until November 8, 2024.
Ireland GloBE Country Guide Updated for the 2024 Finance Bill
On October 10, 2024, Ireland published its 2024 Finance Bill. In the Bill, a number of amendments are made to the Global Minimum Tax provisions. Our Ireland GloBE Country Guide has been updated for relevant changes.
Portugal Approves Pillar 2 Law, Bahamas and Cyprus Table Legislation in Parliament
On October 18, 2024, the Portuguese Parliament approved a law to introduce the EU Minimum Tax Directive into domestic legislation, whilst on October 16, 2024 and October 18, 2024 (respectively), the Bahamas and Cyprus tabled legislation in Parliament to implement Pillar Two.
