Overview of Japan’s Latest Ministerial Ordinance on Pillar 2
On June 30, 2023, Japan’s Ministry of Finance issued Ministry of Finance Ordinance No. 47 of 2023 Amending the Enforcement Regulations of the Corporation Tax Act for Pillar 2 purposes.
The Importance of Substantive Enactment for Pillar Two (Including a Schedule of Domestic Requirements)
Whether Pillar 2 laws are ‘Substantively Enacted’ is of key importance for Pillar 2 tax accounting. This will vary according to a jurisdictions legislative process. We discuss Substantive Enactment globally.
Dutch Finance Minister Expects Agreement on Pillar One Next Week
The Dutch Finance Minister expects the Inclusive Framework (IF) to reach agreement on Pillar One during the IF meetings on 10-12 July, 2023.
How an Inconsistent Approach to Tax Credits Could Drive a Wedge Through Pillar Two
In this article we look at why the correct determination of which tax credits are classed as Qualified Refundable Tax Credits is so important and the significant risks to the application of the Pillar Two rules they potentially pose if there is a non-harmonized approach.
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.
