Malaysia Confirms It Intends To Implement Pillar Two
The Chief Executive of Malaysia’s Inland Revenue Board has confirmed that Malaysia intends to push ahead with the implementation of Pillar Two.
Pillar Two: Domestic Minimum Tax – Interactive Tool
Our Qualified Domestic Minimum Top-Up Tax (QDMTT) interactive tool allows you simulate the impact on your top-up tax liability depending on whether the domestic top-up tax is a QDMTT or is non-qualifying.
Mauritius 2022 Finance Bill includes Pillar Two Top-Up Tax
Mauritius 2022 Finance Act includes Pillar Two Top-Up Tax The Finance (Miscellaneous Provisions) Bill 2022 (subsequently enacted with very minor amendments in the Finance (Miscellaneous Provisions) Act 2022 on August 2, 2022) which implements provisions of the 2022 Budget in Mauritius includes mention of a qualified domestic minimum top-up tax for Pillar Two purposes. It’s a […]
Members Flowchart for the Deferred Tax Adjustment Amount
The Total Deferred Tax Adjustment Amount is a key element of the Pillar Two effective tax rate calculation. See our members flowchart which guides you though the calculation.
Pillar Two GloBE Loss Election – Friend or Foe?
The Pillar Two GloBE loss election can only be made once per jurisdiction. Therefore it’s essential to identity whether this will be beneficial or not. There may be some cases (such as where there is no deferred tax in a jurisdiction or where corporate income tax rates are very low) that this could swing the balance in favour of making an election. But what about the impact of other timing differences? In this article we look at the pro’s and con’s of making a GloBE loss election, including examples to illustrate key issues.
What MNE Groups need to be doing from December 1, 2021
The Pillar Two rules include a number of transitional rules that apply to MNEs from December 1, 2021. In this members article we look at the adjustments and tracking impact for MNE groups.
UK Multinational Top-Up Tax Calculator
The UK published draft legislation on July 20, 2022, to implement a ‘multinational top-up tax’ in line with Pillar Two of the OECDs Two-Pillar Solution. We have produced a calculator to illustrate the key aspects to the calculation of the multinational top-up tax.
A Review of the UK Draft Pillar Two Legislation
The UK published draft legislation on July 20, 2022 to implement Pillar Two from December 31, 2023. Whilst similar to the OECD Model Rules there are differences, not least the treatment of capital gain carry-backs.
UTPR Calculator
This Pillar Two under-taxed payments rule (UTPR) calculator gives an indication of the broad operation of how the top-up tax is allocated to UTPR jurisdictions.
How does Pillar Two Impact Trusts and Foundations?
The Pillar Two rules don’t just apply to companies. They apply to ‘entities’ which can include Trusts and Foundations. The application of the Pillar Two rules to Trusts and Foundations can give rise to a number of issues. Read our member article on some of the practical issues to consider.
