Direct Transposition of the GloBE Rules: Different Approaches By Switzerland & New Zealand
Whilst both jurisdictions are opting for direct transposition of the OECD Model Rules, there is a key difference in how they are drafted.
IASB Publishes Amendments to IAS 12 for the GloBE Rules
Today, the IASB issued the amendments to IAS 12 to take account of the Pillar Two GloBE Rules.
Guernsey, Jersey and the Isle of Man Announce a Global Minimum Tax From 2025
New Zealand Issues Draft Global Minimum Tax Law
Yesterday, New Zealand published a draft law (the Taxation (Annual Rates for 2023–24, Multinational Tax, and Remedial Matters) Bill) to implement the Pillar Two Global Minimum Tax.
G7 Finance Ministers Reaffirm Commitment to Pillars 1 & 2
On May 13, 2023, the G7 finance ministers reaffirmed their commitment to both Pillars One and Two.
Australian Budget Confirms 2024 GloBE Implementation
In todays’ Budget speech, the Australian Government confirmed it will introduce an Income Inclusion Rule, Under-Taxed Profits Rule and a Domestic Minimum Tax.
A Review of the UK QDMTT and the OECD Administrative Guidance
The OECD Administrative Guidance includes a number of specific provisions on the design of a domestic minimum tax to ensure it is a QDMTT. In this article we review the UK’s domestic top-up tax based on the OECD Guidance.
Domestic Implementation of the GloBE Rules: Differing Approaches
A number of jurisdictions have issued legislation (either draft or enacted) to implement the Pillar Two GloBE Rules, however, the approach taken differs significantly. In this article we look at domestic differences not only from the OECD Model Rules, but differences in the implementation of the rules between jurisdictions.
Mapping the Model Rules to the EU Global Minimum Tax Directive
In this article, we map, on an Article-by-Article basis, the EU Directive to the OECD Model Rules and identify provisions in the EU Directive which have no equivalent in the Model Rules.
German Proposals Include a Pillar Two Whitelist
The German Federal Ministry of Justice has proposed a Pillar 2 “white list” for countries whose nominal tax rate is sufficiently above the 15% global minimum rate.
