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.
Amendments to Germany’s Pillar 2 Regime in the Updated Draft Law
On July 10, 2023, the German Ministry of Finance issued an updated draft Pillar 2 law. This includes a number of provisions not included in the original draft bill.
UK Enacts New Multinational Top-Up Tax From December 31, 2023
The Finance (No. 2) Act, 2023 received Royal Assent on July 11, 2023. As such the UK legislation to give effect to the Pillar Two GloBE rules is now enacted.
What Japan’s Cabinet Order on Pillar 2 Includes & Doesn’t Include
Cabinet Order No. 208/2023 accompanies the previous GloBE law and provides further detail on many aspects of the GloBE rules.
OECD Issues Outcome Statement For Pillar 1 and STTR Implementation
Yesterday, the OECD issued an Outcome Statement on Pillars 1 & 2 that gives an update on the status and timeline for implementation of Amount A and B of Pillar One, and the Subject-to-Tax Rule (STTR).
Key Drivers: Differences in the Pillar 2 ETR & Domestic Rate
In this article we look at some of the key drivers that can result in Pillar 2 ETR’s being significantly different to the headline domestic tax rate.
Tracking Deferred Tax Adjustments for Pillar Two
A number of the adjustments to the deferred tax expense under Pillar 2 will mean significant changes to ERP systems. See our list of all required adjustments.
