Pillar Two GloBE Rules and Estonia’s Distribution Tax
A key issue with a distribution tax regime such as Estonia’s is that a company may not distribute profits for a number of years. They would have GloBE income but no or limited tax suffered on that income which would lead to a sizeable Pillar Two top-up tax liability. As such a distribution tax regime election is available.
Israel Reaffirms Pillar Two Implementation
Local media reports state that Israel’s Finance Minister has reaffirmed Israel’s commitment to adopting the Pillar Two rules.
A Review of the Danish Draft Minimum Tax Act
On June 23, 2023, the Danish Ministry of Taxation issued the draft Minimum Tax Act to give effect to the GloBE rules.
A Review of the Czech Draft Top-Up Tax Act
On May 15, 2023, the Czech Republic issued the Draft Top-up Tax Act, (along with Explanatory Notes) to give effect to the GloBE rules,
Overview of Japan’s Cabinet Order on the Global Minimum Tax
On June 16, 2023, Cabinet Order No. 208 was published in Japan’s Official Gazette. This provides much more detail on various aspects of the Pillar Two GloBE rules in Japan from April 1, 2024.
Pillar Two: AI-Powered Research Tool
Members have access to our Pillar Two AI-powered Analysis Tool. This is a custom AI model trained on Pillar Two data from our members-only content including our Pillar Two Navigator and Jurisdictional analysis.
UK Issues First Tranche of Draft Guidance on Global Minimum Tax
On June 15, 2023, the UK issued draft guidance on the application of the multinational top-up tax which will apply for accounting periods beginning on or after December 31, 2023.
Japan Issues Cabinet Order With More Details On Pillar Two Application
On June 16, 2023, a Cabinet Order to Partially Amend the Enforcement Order of the Corporation Tax Law for Pillar 2 was published in the Official Gazette.
Swiss Referendum Approves 2024 Global Minimum Tax
The Swiss referendum on June 18, 2023 approved the introduction of a global minimum tax from January 1, 2024
How Pillar Two Applies To Trusts & Foundations
The Pillar Two rules don’t just apply to companies. They apply to ‘entities’. In this article we look at the application of Pillar Two to trusts and foundations.
