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.
GloBE Country Guide: Japan – Update
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Japan from April 1, 2024, as updated by the detailed implementation guidance issued by the Ministry of Finance on October 20, 2023,
Lithuania Issues Draft Pillar Two Law & Confirms Postponement
On October 27, 2023, Lithuania’s Ministry of Finance issued a draft law to implement the EU Global Minimum Tax Directive (along with a Draft Law on the Amendment of Article 589 of the Code of Administrative Offenses).
EU Official Suggests 5 States to Delay Pillar Two
On October 27, 2023, it was suggested by an EU official that Estonia, Latvia, Lithuania, Malta, and Slovakia are to delay the implementation of the IIR and UTPR under the Pillar Two rules.
Pillar Two Navigator Update: Intra-Group Asset Transfers
Updated analysis of the treatment of intra-group asset transfers under the GloBE rules, including the step-up denial and examples of the impact of claiming a deferred tax asset under the OECD Administrative Guidance.
Kuwait Considers Pillar Two Application
It was reported on October 23, 2023, that Kuwait is considering a comprehensive overhaul of its tax laws from January 1, 2025 to apply a 15 percent corporate tax on the profits of all legal persons, including major international companies.
GloBE Country Guide: Hungary
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Hungary from 2024.
