Domestic Implementation of the GloBE Rules: Differing Approaches
A number of jurisdictions have issued legislation (either draft or enacted) to implement the Pillar Two GloBE Rules, however, the approach taken differs significantly. In this article we look at domestic differences not only from the OECD Model Rules, but differences in the implementation of the rules between jurisdictions.
Mapping the Model Rules to the EU Global Minimum Tax Directive
In this article, we map, on an Article-by-Article basis, the EU Directive to the OECD Model Rules and identify provisions in the EU Directive which have no equivalent in the Model Rules.
German Proposals Include a Pillar Two Whitelist
The German Federal Ministry of Justice has proposed a Pillar 2 “white list” for countries whose nominal tax rate is sufficiently above the 15% global minimum rate.
Sourcing the UK Draft Pillar Two Legislation to the OECD Model Rules
Our table sources all of the Articles in the OECD Model Rules to the relevant provision in the UK draft legislation. It also includes notes where there are differences from the provisions in the Model Rules.
Key Differences in Excluded Entities Between The OECD Model Rules & UK Draft Legislation
In this article we highlight key differences between the UK approach to Excluded Entities in the draft GloBE legislation and the approach taken in the OECD Model Rules.
UK Proposes Amendments to Global Minimum Tax Rules
The UK proposed some minor technical changes to the domestic implementation of the Pillar Two GloBE rules on April 14, 2023.
Nigeria Reconsidering Its Approach To Pillar Two
Nigeria may be reconsidering its approach to Pillar 2 following an April 2023 workshop jointly organised by the OECD and the Federal Inland Revenue Service (FIRS).
Australia’s Public CbCR Rule To Include GloBE ETR
Australia issued an Exposure Draft for Multinational Tax Transparency Reporting last week to provide for global public country-by-country reporting for many large multinational enterprises (MNEs) operating in Australia. This includes the GloBE ETR.
Vietnam Aims To Submit Pillar 2 Law In June 2023
Local reports state that the Ministry of Finance is collecting feedback on its proposals to develop the Global Minimum Tax Law and will submit it to the Government in June 2023. Submission to the National Assembly is planned for its 6th Session in October 2023.
IASB Issues Staff Papers on Updated Pillar 2 Tax Accounting Proposals
Last week, the IASB released five Staff Papers providing an update to tax accounting under IFRS for Pillar Two. The IASB had previously issued an Exposure Draft for proposed amendments to IAS 12 to take account of the Pillar Two Model Rules.
