Germany Includes an Amendment to its GMT Law in the Draft Annual Tax Act
On June 5, 2024, the German Federal Ministry of Finance published the government draft for an Annual Tax Act 2024. Article 32 includes an amendment to the minimum tax act to implement a provision from the July 2023 OECD Administrative Guidance.
OECD Administrative Guidance Tracker Updated For June 2024 Guidance
Our OECD Administrative Guidance Tracker has been updated for the latest amendments in the June 2024 Administrative Guidance.
Canada GloBE Country Guide Updated for Gazetted GMT Law
On June 20, 2024, the Global Minimum Tax Act (included in the Budget Implementation Act 2024, No. 1) received royal assent. This includes provisions to implement an IIR and a QDMTT from December 31, 2023:
QDMTT Tracker Updated for the June 2024 OECD Administrative Guidance
Our QDMTT Legislative Tracker has been updated for the amendments to the design of QDMTTs, as provided in the June 2024 OECD Administrative Guidance.
Lithuania and Latvia Updates to the GloBE Country Guides
Updates to the GloBE Country Guides for Latvia and Lithuania following the publication of their laws to implement Art 50 of the EU Minimum Tax Directive in the Official Gazette.
New Guidance for the GloBE Treatment of Securitization Entities
The Fourth Set of OECD Administrative Guidance (issued on June 17, 2024) includes guidance on the treatment of Securitization Entities.
OECD Issues Clarifications and Amendments to GloBE Flow-Through Taxation
Section 5 of the Fourth Set of OECD Administrative Guidance (published on June 17, 2024) provides clarifications on the allocation of both profits and taxes of Flow-through Entities (including both hybrid entities and reverse hybrid entities). Most of these changes are to ensure the consistent matching of income and taxes in the same entity.
The Transitional Qualification Mechanism for IIRs and Domestic Minimum Taxes
On June 17, 2024, the OECD provided more information on the Transitional Qualification Mechanism for determining the qualified status of IIRs and Domestic Minimum Taxes
OECD Provides More Guidance on GloBE Carrying Values and Separate GloBE Deferred Tax Calculations
Section 2 of the Fourth Set of OECD Administrative Guidance (issued on June 17, 2024) provides details of the use of GloBE carrying values and the impact that these will have on the GloBE ETR calculation.
Analysis of the Application of the DTL Recapture Rule in the OECDs June 2024 Administrative Guidance
Section 1 of the Fourth Set of OECD Administrative Guidance (issued on June 17, 2024) provides further details on the deferred tax liability recapture rule. Read our detailed analysis.
