UK Issues First Tranche of Draft Guidance on Global Minimum Tax
On June 15, 2023, the UK issued draft guidance on the application of the multinational top-up tax which will apply for accounting periods beginning on or after December 31, 2023.
Japan Issues Cabinet Order With More Details On Pillar Two Application
On June 16, 2023, a Cabinet Order to Partially Amend the Enforcement Order of the Corporation Tax Law for Pillar 2 was published in the Official Gazette.
Swiss Referendum Approves 2024 Global Minimum Tax
The Swiss referendum on June 18, 2023 approved the introduction of a global minimum tax from January 1, 2024
How Pillar Two Applies To Trusts & Foundations
The Pillar Two rules don’t just apply to companies. They apply to ‘entities’. In this article we look at the application of Pillar Two to trusts and foundations.
Pillar Two and Transfer Pricing
The Pillar Two Rules generally require transactions between entities located in different jurisdictions to be priced at an arms-length basis. However, special rules apply to unilateral transfer pricing adjustments given the risk of income either being taxed twice or not taxed at all.
Pillar Two Elections: Jurisdictional Matrix
Use our jurisdictional matrix to track the domestic implementation of Pillar Two elections in the current domestic draft or enacted law.
Norway Issues Consultation and Draft Law For Pillar 2 Rules
Yesterday, the Norwegian Ministry of Finance launched a consultation (including draft legislation) on the implementation of the Pillar Two GloBE Rules in Norway.
IMF Recommends Extension of Kuwait’s CIT For GloBE Implementation
In yesterdays concluding statement of the IMF 2023 Article IV mission to Kuwait, the IMF recommended that the 15 percent corporate income tax should be expanded to cover domestic firms, to bring Kuwait into line with the GloBE rules.
IASB Proposing Amendments to IFRS For SME’s For Pillar 2 Rules
On June 1, 2023, the International Accounting Standards Board issued an Exposure Draft for Proposed Amendments to the IFRS for SMEs Standard to take account of the Pillar Two Rules.
The Netherlands Sends GloBE Minimum Tax Bill to Parliament
The Netherlands presented the Minimum Tax Bill, 2024 to Parliament yesterday. It implements an Income Inclusion Rule and a Qualified Domestic Minimum Top-Up Tax for financial years commencing on or after December 31, 2023. An Under-Taxed Profits Rule applies for financial years commencing on or after December 31, 2024.
