Finland Issues Guidance for the Application of the Global Minimum Tax
On March 10, 2025 and March 12, 2025, Finland issued explanatory guidance on the application of the Minimum Tax Act, including provisions from the OECD June 2024 Administrative Guidance relating to the DTL recapture.
Spain Issues Regulations for the Global Minimum Tax Act
On April 2, 2025, Spain issued Regulations for the application of the Global Minimum Tax Law. This includes a number of aspects of the OECD Administrative Guidance.
The Treatment of Permanent Establishments under Pillar Two
Permanent Establishments (PEs) are subject to a number of specific rules under Pillar Two in order to apply the general provisions to them. Key issues are what is a PE under Pillar Two? where is it located? and how are income and taxes allocated to it?
UK Issues a List of Jurisdictions that Have Qualified IIRs and DMTTs for Pillar 2
On March 21, 2025, the UK approved a list of jurisdictions that have qualified status for the purposes of the income inclusion rule and domestic minimum tax (including the QDMTT Safe Harbour).
GloBE Country Guide: Qatar
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Qatar for accounting periods beginning on or after January 1, 2025.
Qatar Enacts a Pillar Two Income Inclusion Rule and Domestic Minimum Tax
On March 27, 2025, Law No. 22 of 2024 was published in Qatar’s Official Gazette. This implements the Pillar Two Income Inclusion Rule and a Domestic Minimum Top- Up Tax from January 1, 2025.
Bulgaria Gazettes its 2025 Budget Law which Includes Numerous Changes to the Global Minimum Tax Regime
On March 27, 2025, Bulgaria’s 2025 State Budget Law (the ‘2025 Budget Law’) was published in the Official Gazette. This includes a number of changes to the Corporate Income Tax Law to amend the Global Minimum Tax provisions from January 1, 2024.
Insurance Investment Entities and Pillar Two
Insurance Investment Entities are subject to special treatment under the Pillar Two GloBE Rules. Read our analysis of the key provisions.
Liechtenstein Government Approves a Draft Law for the Exchange of GIR Information Under the MCAA
On March 18, 2025, the government approved a draft bill on the amendment of Liechtenstein’s Global Minimum Tax Act (‘the bill’). The bill is intended to implement domestically the OECD provisions for the exchange of information in the GloBE Information Return (GIR) under the multilateral agreement between competent authorities on the exchange of GloBE information (GIR MCAA).
Italy Issues Decree for Double Filing Relief Notification Under the Pillar 2 Rules
On March 6, 2025 a Decree of the Italian Ministry of Finance on Notification Requirements for Global Minimum Tax purposes was published in the Official Gazette. This provides more details on the double filing relief notification under Article 51(4) of Legislative Decree December 27, 2023, no. 209 (the Global Minimum Tax Law).
