A Review of Italy’s Draft Pillar Two Law

On September 11, 2023, the Italian Ministry of Finance issued a draft law for the implementation of the EU Global Minimum Tax Directive. Read our detailed review.
International Participation Exemption Regimes & Pillar Two

The requirements for a participation exemption under domestic law may not match the exemption requirements in the Pillar Two Rules. Read our analysis.
GloBE Country Guide: Germany

Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Germany from 2024. Updated for the August 16, 2023 Draft Law.
Taiwan Confirms No Pillar 2 Schedule, But An Increase To Its Domestic Minimum Tax Rate From 2024

Taiwan’s Ministry of Finance confirmed today there is no set schedule for the introduction of the Pillar 2 GloBE rules in Taiwan. Taiwan’s Ministry of Finance has previously stated it will prepare draft legislation for the government to increase Taiwan’s domestic minimum tax rate from 12% to 15%.
However, this creates a number of issues in terms of its interaction with the Pillar Two global minimum tax.
Pillar Two Elections Matrix Updated

Our Pillar 2 Jurisdictional Elections Matrix has been updated for the latest draft laws issued/amended, including the recent Czech update.
Sourcing the Japanese Pillar Two Law, Cabinet Order and Ministerial Ordinance to the OECD Model Rules

An article by article analysis that sources all of the articles of the Japanese Pillar Two Law, Cabinet Order and Ministerial Ordinance back to the OECD Model Rules, including notes where there are differences from the provisions in the Model Rules.
A Review of Japan’s Latest Pillar Two Ordinance

Japan has issued three pieces of legislation to implement the Pillar Two GloBE Rules. In this article we look at the final piece (to date) in Japan’s GloBE law – the Ministerial Ordinance.
GloBE Country Guide: Canada

Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Canada for accounting periods beginning on or after 31 December, 2023.
A Review of Canada’s Draft GloBE Law

On August 4, 2023, Canada issued the draft Global Minimum Tax Act (the ‘draft law’) for consultation.
Key Aspects of Finland’s Draft GloBE Law

On August 15, 2023, the Finnish Ministry of Finance issued a draft law for the implementation of the EU Global Minimum Tax Directive