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.
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.
