Sourcing the South Korean Pillar Two Law to the OECD Model Rules
An article by article analysis that sources all of the articles of the South Korean Pillar Two legislation (the original Law, Amended Law and Amended Enforcement Decree) back to the OECD Model Rules.
GloBE Country Guide – Germany: Updated
Analysis of the implementation of the EU Global Minimum Tax Directive in Germany, taking account of the changes made in the recent draft law, approved by the Bundestag on November 10, 2023.
GloBE Country Guide – South Korea: Updated
Our South Korea GloBE Country Guide chapter has been updated for the recent amendment to the Enforcement Decree of the International Tax Adjustment Act which provides additional detail for the operation of the GloBE rules.
Germany Approves and Updates its GloBE Law
On November 10, 2023, the Bundestag (lower house) approved the German draft law to implement the EU Minimum Tax Directive.
A Review of South Korea’s Latest GloBE Amendments
The Amended Enforcement Decree implements most aspects of the February and July 2023 OECD Administrative Guidance. Read our analysis.
South Korea Issues Amended Enforcement Decree for Detailed GloBE Rules
On November 9, 2023, South Korea issued the Preliminary Legislative Notice of Partial Amendment to the Enforcement Decree of the International Tax Mediation Act.
Bermuda and Barbados Announce GloBE Implementation
Bermuda and Barbados announced on November 3 and 7, 2023 (respectively) their intention to implement the Pillar 2 GloBE rules (albeit with different approaches).
Detailed Analysis of the Transitional CbCR Safe Harbour
The Transitional CbCR Safe Harbour is included in the OECD Safe Harbour and Penalty Relief Guidance and where it applies it deems the jurisdictional top-up tax to be zero. Read our detailed analysis.
A Review of Malaysia’s Draft Pillar Two Law
Today, the Finance (No. 2) Bill, 2023 (the ‘draft law’) had its first reading before the Malaysian Parliament. This inserts a new Part XI into the Income Tax Act, 1967 to implement the GloBE rules.
Qatar Considers Implementing a QDMTT
Qatar’s General Tax Authority closed its three-day regional workshop on the Pillar Two global minimum tax.
