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.
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.
