Switzerland Approves GloBE Rules and Azerbaijan Joins the 2-Pillar Solution
December 16, 2022 saw more developments on the international implementation of Pillar Two. The Swiss parliament approved the draft constitutional amendment for enacting the GloBE rules and Azerbaijan joins the 2-Pillar solution.
Poland Withdraws its Veto and the EU Pillar Two Directive is Adopted
Last night the Council of the European Union formally adopted (among other things) the EU Pillar Two directive as Poland pulled its veto at the last minute.
Poland Holds Up EU Pillar Two Directive
Following the recent preliminary agreement reached in the EU Council on the implementation of Pillar Two, Poland had asked for further time to consider the implementation of the EU Directive.
UAEs New Corporate Tax Law and Pillar Two
On 9 December 2022, the UAE issued the Federal Decree-Law No. (47) of 2022 on the taxation of corporations and businesses. In this article we look at the new UAE CT Law from a Pillar Two perspective.
Full Steam Ahead For EU Pillar Two Implementation
The EU Council has reached agreement on the implementation of Pillar Two. As Pillar Two gains momentum the critical mass of countries required for effective implementation gets closer.
Today’s OECD Consultation Document on Amount B of Pillar One
The OECD published a consultation document on Amount B of Pillar One today. We take an initial look at the key aspects of the Amount B consultation.
Thailand’s Tax Incentive Regime and Pillar Two
In this article, we take a look at Thailand’s tax regime from a Pillar Two perspective, with a particular focus on their tax incentives.
New Zealands Approach to Pillar Two
There are features of the NZ regime that raise issues from a Pillar Two perspective. Some of these were addressed in a Pillar Two consultation document issued earlier this year. In this article we look at some of the key issues in the implementation of Pillar Two for New Zealand.
Profit Shifting to CFCs to Reduce Pillar 2 Top-Up Tax
Article 4.3.2(c) of the OECD Model Rules allocates tax paid on CFC income to the CFC entity (subject to a pushdown limitation). However, this leads to a situation where an MNE can reduce potential top-up tax by allocating more income to a CFC entity.
VAT on Digital Services Tracker: Updated
Our Global VAT on Digital Services Tracker has been updated and now covers over 80 jurisdictions.
