Paraguay’s Significant Pillar Two Risk
Paraguay stands out amongst most South American countries as being the one most at risk of substantial jurisdictional top-up tax for in-scope groups under Pillar Two.
Director of Indonesian Tax Authority Confirms Planned 2024 GloBE Implementation
The Director of International Taxation of the Directorate General of Taxes has confirmed Indonesia is planning to implement the Pillar Two GloBE Rules from 2024. This is unlike Singapore which has delayed the implementation until 2025.
Impact of the Staggered Implementation of the GloBE Rules
The global implementation of the GloBE rules is staggered with different jurisdictions applying both the Income Inclusion Rule (IIR) and the Under-Taxed Payments Rule (UTPR) from different dates.
Malaysia: Pillar Two Implementation Expected in February 24 Budget
It is expected that the Pillar Two global minimum tax may be among the measures implemented in Budget 2023 on February 24, 2023.
Singapore To Implement Pillar Two From 2025
In the 2023 Budget Speech, the Singapore government announced it is to implement Pillar Two from 2025.
Treatment of CFC Taxes: QDMTTs vs GloBE Rules
Under Article 4.3.2(c) of the OECD Model Rules, tax paid under a CFC regime is generally allocated for GloBE purposes to the CFC entity. However, Article 5.1.3 of the OECD Administrative Guidance confirms that this is not the case for Qualified Domestic Minimum Top-Up Taxes (QDMTTs).
Pillar 2 Navigator Update for OECD Administrative Guidance: GloBE Adjustments
The Pillar Two Navigator – GloBE Adjustments chapter has been updated for the OECD Administrative Guidance.
Pillar Two Elections Updated For OECD Administrative Guidance
The OECD Administrative Guidance included a number of new elections available to MNEs to simplify or minimise some of the adverse impacts of the GloBE Rules. We have updated our Pillar Two Elections product to include all GloBE Elections.
Vietnam Needs to Act Fast After The South Korean Pillar Two Law
One of the tools to attract FDI to Vietnam is tax incentives. However, from the beginning of 2024, applying the Global Minimum Tax Rule at 15% will reduce Vietnam’s competitiveness. Although corporate income tax is currently at 20%, Vietnam applies a number of tax incentives.
The Equity Investment Inclusion Election
Article 2.9 of the OECD Administrative Guidance provides for an Equity Investment Inclusion Election. This relates, in part, to the interaction of Articles 3.2.1(c) and 4.1.3(a) of the OECD Model Rules.
