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.
Greece Enacts Pillar Two Law
On April 5, 2024, Law 5100/2024 was published in the Official Gazette. This implements the EU Minimum Tax Directive in Greece from December 31, 2023 (with the UTPR applying from December 31, 2024).
GloBE Country Guide: Liechtenstein
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Liechtenstein from 2024. Updated for the GloBE Regulation of March 28, 2024.
GloBE Country Guide: New Zealand
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in New Zealand. Updated for the enacted legislation on March 28, 2024.
A Review of the Liechtenstein GloBE Regulation
On March 28, 2024, the Decree on the minimum taxation of large groups of undertakings (the ‘GloBE Regulation’) was published in the Official Gazette.
New Zealand Enacts GloBE Law and Liechtenstein Issues GloBE Regulations
On March 28, 2024, the GloBE Regulations were published in the Liechtenstein Official Gazette and New Zealand’s Pillar Two Law received Royal Assent.
GloBE Country Guide: Australia
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Australia for accounting periods beginning on or after January 1, 2024. Updated for the draft legislation issued by the Australian Treasury on March 21, 2024.
Sweden Issues Proposed Draft Legislation to Implement OECD Administrative Guidance
On March 19, 2024, the Swedish Ministry of Finance issued a proposal (including Draft Legislation and Explanatory Notes) to amend its Pillar Two law to include relevant provisions of the OECD Administrative Guidance.
