Interaction Between Bonus Depreciation and the Substance-Based Income Exclusion
In this article we look at the interaction between deferred tax on bonus depreciation and the substance-based income exclusion on investments in tangible assets.
French 2025 Finance Act Includes Pillar 2 Changes for OECD Administrative Guidance
On February 15, 2025, Law 2025-127 of February 15, 2025 (the 2025 Finance Act) was published in the French Official Gazette. This includes a number of amendments to the Pillar 2 regime from December 31, 2024.
Foreign Tax Credits and the Pillar Two GloBE Rules
Foreign tax credits interact with the Pillar Two GloBE Rules in a number of ways. In this article we assess the key impact.
Pillar Two: Trusts & Foundations
The Pillar Two rules don’t just apply to companies. They apply to ‘entities’. This means that the Pillar Two GloBE rules can apply to both trusts and foundations.
Pension Funds & Pillar Two
Pension funds are subject to a number of specific provisions under the Pillar Two rules. In this article we look at some of the key aspects of Pillar Two that impact on Pension Funds.
Poland Issues a List of Jurisdictions that Have Qualified IIRs and DMTTs for Pillar 2
On February 12, 2025, Poland issued a list of jurisdictions that have qualified status for the purposes of the income inclusion rule and domestic minimum tax (including the QDMTT Safe Harbour).
Practical Implications of Pillar 2 Compliance after the January 2025 OECD Guidance
In January 2025, the OECD provided some much-needed guidance on the operation of the Pillar 2 GloBE rules. This Orbitax article provides an analysis of the impact of the guidance on Pillar 2 compliance.
UAE Issues a Cabinet Decision on the Pillar Two Domestic Minimum Tax
In this article we look at the implementation of the Pillar 2 Domestic Minimum Tax in the United Arab Emirates, based on Cabinet Decision 142 of 2024 issued on February 8, 2025
GloBE Country Guide: The UAE
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in the United Arab Emirates for accounting periods beginning on or after January 1, 2025. Updated for the Cabinet Decision issued on February 8, 2025.
A Detailed Review of the Implementation of the Global Minimum Tax in Germany
In this article we look at the implementation of the Pillar 2 Global Minimum Tax in Germany, including the implementation of the OECD Administrative Guidance.
