Belgium’s Pillar Two Notification Form Requires Significant Data Input
On May 21, 2024, the Belgian Tax Authority issued further details on the notification requirements for in-scope MNE groups. This includes significant information on the group structure.
Czech Republic GloBE Guide Updated for the April 2024 Draft Law Amendments
Analysis of the Pillar Two GloBE rules in the Czech republic, updated for the April 26, 2024, draft law to reflect various aspects of the OECD Administrative Guidance (particularly the December 2023 amendments).
Jersey to implement an IIR and QDMTT from January 1, 2025
On May 22, 2024, Jersey announced it will be implementing an Income Inclusion Rule (IIR) and a new standalone multinational corporate income tax for accounting periods beginning on or after January 1, 2025.
Denmark GloBE Guide Updated for the Draft Law of April 30, 2024
On April 30, 2024, a Draft Law to amend the Danish Minimum Taxation Act was submitted to the Danish Parliament. This implements additional aspects of the OECD Administrative Guidance.
Isle of Man Announces QDMTT From 2025
On May 20, 2024, the Isle of Man Government issued a press release stating it intends to introduce a Qualified Domestic Minimum Top-Up Tax (QDMTT) with effect from January 1, 2025.
Reviewing MNE Group Structures for Profit Extraction after Pillar Two
The specific treatment of dividends and other distributions under the Pillar Two GloBE Rules raises some interesting issues and opportunities in blending such payments between otherwise low-taxed entities and holding companies to reduce any potential top-up tax liability.
Kenya Includes a Domestic Minimum Tax in its 2024 Finance Bill
On May 13, 2024, the Finance Bill, 2024 was sent to the Kenyan Parliament. It includes provisions to introduce a 15% domestic minimum top-up tax from January 1, 2025.
Data Points For the Transitional CbCR Safe Harbour
The Transitional CbCR Safe Harbour is a short-term measure that will allow an MNE to avoid undertaking detailed GloBE calculations for a jurisdiction if certain requirements are met. Data will need to be extracted from the CbC Report, financial statements and ERP and EPM systems. Group structure information will also be required.
Estonia’s Pillar Two Law Enacted: Updated GloBE Guide
On May 2, 2024, the Estonian Official Gazette enacted the ‘Act supplementing the Tax Information Exchange Act, the Tax Administration Act and the Income Tax Act’ to implement Article 50 of the EU Minimum Tax Directive.
Updated GloBE Guide: Canada
Analysis of the implementation of the Pillar Two GloBE rules for Canada, updated for the Budget Implementation Bill, 2024, No. 1, issued on April 30, 2024.
