Canada Issues Draft Global Minimum Tax Act
On August 4, 2023, Canada issued the draft Global Minimum Tax Act for consultation. The consultation closes on September 8, 2023.
Slovakia Issues Draft Pillar Two Law
On August 3, 2023, Slovakia issued a draft Pillar Two law, which includes an IIR, UTPR and a QDMTT.
Ireland GloBE Country Guide: Updated
The GloBE Country Guide for Ireland has been updated for the Irish Second Feedback Statement issued on July 27, 2023.
Ireland Issues Second Feedback Statement on Pillar Two
On July 27, 2023, Ireland issued its Second Feedback Statement on the Pillar Two GloBE Rules. This includes draft legislation for the Transitional CbCR and UTPR Safe Harbours and the QDMTT.
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.
