South Korea Issues Draft Pillar 2 Amendment Law
On July 28, 2023, the South Korean government published the Partial Amendment Proposal for the International Tax Adjustment Act, to amend their Pillar Two law to (1) take account of a number of OECD amendments issued in their Administrative Guidance, and (2) delay the implementation of the UTPR until January 1, 2025.
Luxembourg Government Approves Pillar Two Bill
On 28 July 2023, the Government approved the draft law aimed at transposing the EU Minimum Tax Directive into Luxembourg law.
How the QDMTT Safe Harbour Applies
The QDMTT Safe Harbour excludes the application of the GloBE Rules in other jurisdictions by deeming the Top-up Tax payable under the GloBE Rules to be nil where top-up tax is levied under a QDMTT. In this article, we look at how it applies.
Analysis of the OECDs Model Provision for the Subject-to-Tax Rule (STTR)
On July 17, 2023, the OECD issued the model provision and commentary for the STTR. In this report we analyse the operation of the STTR based on this latest guidance.
QDMTT Legislative Tracker Updated for Latest Administrative Guidance
We have updated our QDMTT Legislative Tracker to include details of the amendments to the design of QDMTTs in the July 2023 Administrative Guidance.
Review of the UK Draft UTPR Law
The UK released draft legislation for the Under-Taxed Profits Rule (UTPR) on July 17, 2023. Read our review.
Key Aspects of the GloBE Information Return Guidance
On July 17, 2023, the OECD issued the standardised GloBE Information Return (GIR) that must be submitted by MNE groups within the scope of the GloBE rules.
QDMTT Design Features After The Latest OECD Administrative Guidance
The Second Set of OECD Administrative Guidance includes a number of additions to the design features of a QDMTT. Read more in this article.
A Review of the OECDs Second Set of GloBE Administrative Guidance
On July 17, 2023, the OECD issued its second set of Administrative Guidance on the application of the Pillar Two GloBE Rules. This follows the first set of Administrative Guidance that was issued in February 2023.
The OECD Issues a Model STTR Provision and Commentary
Today, the OECD issued the model provision for the Subject-to-tax Rule (STTR) and its commentary.
