GloBE Country Guide: The Bahamas
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in The Bahamas for accounting periods beginning on or after January 1, 2025. Updated for the draft legislation issued by The Bahamas Government on August 12, 2024.
GloBE Country Guide: Jersey
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Jersey for accounting periods beginning on or after January 1, 2025. Updated for the draft legislation issued on August 14, 2024.
Austria Updates Minimum Tax Act for Aspects of OECD Administrative Guidance
Updated Pillar 2 GloBE guide for Austria following OECD Administrative Guidance, including currency provisions and extending the Transitional CbCR Safe Harbour to cases where an MNE is not required to prepare CbC
Finland Issues Draft Pillar 2 Amendment Law to Reflect OECD Administrative Guidance
On August 12, 2024, the Finnish government issued draft legislation to amend the Minimum Tax Act to reflect numerous aspects of the OECD Administrative Guidance. The draft law is subject to a consultation until September 6, 2024, and once enacted will apply from January 1, 2024.
Bermuda Issues a Consultation for CIT Administrative Rules
On August 8, 2024, the Bermuda Ministry of Finance issued a consultation on the administrative provisions for the new corporate income tax that is to apply from 2025
Turkey Enacts its Pillar Two Law
The “Law on the Amendment of Tax Laws and Certain Laws” was published in the Turkish Official Gazette on August 2, 2024. Articles 37 – 50 of the Law include provisions to implement the GloBE rules in domestic law from January 1, 2024. This includes the IIR, UTPR and a domestic minimum top-up tax.
South Korea’s 2024 Tax Law Amendment Bill Includes Pillar 2 Updates
On July 25, 2024, the Ministry of Economy and Finance issued the 2024 Tax Law Amendment Bill. This includes a number of amendments to the South Korean global minimum tax law to reflect aspects of the OECD Administrative Guidance.
UK Issues Draft Legislation for the Hybrid Arbitrage Anti-Avoidance Rule
On July 29, 2024, the UK government issued draft legislation for the implementation of the Pillar Two anti-avoidance rules targeting Hybrid Arbitrage Arrangements.
Israel to Apply a QDMTT from 2026
On July 29, 2024, the Israeli Ministry of Finance announced it will implement a QDMTT from January 1, 2026. The IIR and UTPR will not be introduced at that point and further consideration will be given to their implementation after a review of the effectiveness of the QDMTT.
Denmark GloBE Country Guide: Updated for June 2024 Amending Law
On June 11, 2024, Law No. 684 was published in the Danish Official Gazette. This implements additional aspects of the OECD Administrative Guidance.
