Germany Confirms Pillar Two Law to be Gazetted in 2023
German Finance Minister Christian Lindner (FDP) has announced the presentation of a “tax fairness law” and a tax “growth package” for 2023. It was also confirmed the Law to implement the Pillar Two GloBE Rules will be gazetted in 2023.
Pillar 2 Navigator Update: Additional Top-Up Tax & Excess Negative Tax Expense Carry-Forwards
As an alternative to incurring additional top-up tax when a domestic tax loss exceeds the GloBE loss, Article 2.7 of the OECD Administrative Guidance provides that an MNE can elect for the Excess Negative Tax Expense administrative procedure.
Pillar 2 Navigator Update: Deferred Tax & Substitute Loss Carry Forwards
Article 2.8 of the OECD Administrative Guidance provides for the inclusion of deferred tax in the GloBE deferred tax adjustment amount for ‘Substitute Loss Carry Forwards’.
Japan Submits Draft Pillar Two Law to Parliament
On February 3 and 6, 2023, the Ministry of Finance published the “Bill for Partial Revision of the Income Tax Act” This includes the proposed implementation of the Pillar Two GloBE rules from April 2024.
Blended CFC Calculator
For fiscal years that begin on or before 31 December 2025 but not ending after 30 June 2027, the OECD Administrative Guidance includes a simplified formula to allocate CFC taxes in blended CFC regime. Use our simple calculator.
Qatar: First Arab State to Introduce 15% Minimum Tax
Qatar is the first Arab state to introduce a 15% minimum tax in Law 11 of 2022, issued on February 2, 2023.
Designing a Qualified Domestic Minimum Top-Up Tax (QDMTT)
The OECD Administrative Guidance provides details on which aspects of the GloBE Rules need to be reflected in the QDMTT regime and which aspects don’t.
GILTI & Blended CFC Regimes
Article 2.10 of the Administrative Guidance provides more information on the treatment of the US Global Intangible Low-Taxed Income (GILTI) regime.
OECD Issues the Agreed Administrative Guidance for the GloBE Rules
Today the OECD has issued the Agreed Administrative Guidance for the Pillar Two GloBE Rules. This is the final part of the implementation framework for the GloBE Rules.
OECD Issues the Agreed Administrative Guidance for the GloBE Rules
Today the OECD has issued the Agreed Administrative Guidance for the Pillar Two GloBE Rules. This is the final part of the implementation framework for the GloBE Rules.
