Why Decentralized Data Management is required for Pillar Two
Whether multinationals adopt a centralized or decentralized approach to Pillar Two will be one of the key factors in correctly establishing the systems and architecture to collect, manage, analyse and store source data for the Pillar Two effective tax rate and top-up tax calculation.
GloBE Country Guide: Poland
On April 25, 2024, the Polish Ministry of Finance issued a draft law to implement the EU Minimum Tax Directive into domestic law. Read our review of the draft law.
GloBE Country Guide: Poland
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Poland on or after January 1, 2025. Updated for the draft legislation issued by the Polish Ministry of Finance on April 25, 2024.
Why Tax Data Mapping for Pillar Two is Crucial
The tax data mapping assessment is the cornerstone for MNEs looking to implement an effective approach to manage Pillar Two. All systems changes flow from this.
GloBE Country Guide: Barbados
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Barbados for accounting periods beginning on or after January 1, 2024. Updated for the draft legislation being considered by the Barbadian Parliament.
Joint Ventures and the Allocation of Pillar Two Top-Up Tax
The Pillar Two rules include specific rules for Joint Ventures (JVs) that would otherwise not be within the scope of Pillar Two due to not being consolidated in the financial accounts of the MNE group. However, of more interest is how the amount of top-tax tax (and by implication the amount not collected) varies depending on the JV group structure. Read more in this article.
A Review of South Korea’s Pillar Two Amendments to its Enforcement Regulation
On March 22, 2024, the Decree of the Ministry of Economy and Finance No. 1048, to amend the Enforcement Regulations of the International Tax Adjustment Act entered into force.
South Korea Releases Pillar Two Forms, Including GloBE Information Return & GloBE Tax Return
On March 22, 2024, the Enforcement Regulations to the International Tax Adjustment Act were amended. This includes attachments for the GIR (in English and Korean), the GloBE Tax Return and the Notification Form for a Foreign CE to File the GIR.
The New Zealand and EU Approaches to the Domestic Income Inclusion Rule (DIIR)
Whilst the OECD Model Rules require the application of the IIR to Low-Taxed Constituent Entities outside the jurisdiction, the Commentary permits the application of the IIR domestically (a ‘DIIR’). Both New Zealand and the EU apply a DIIR.
Greek GloBE Country Guide Updated for Enacted Pillar Two Law
Analysis of the Pillar Two GloBE rules in Greece – updated for Law 5100/2024 of April 5, 2024 implementing the EU Minimum tax Directive.
