The Treatment of Tax Transparent Entities Under Pillar Two
The Pillar Two Rules include specific provisions for tax transparent entities to avoid artificially low effective tax rates and significant top-up tax, particularly for tax transparent UPEs.
The Impact of Pillar 2 on Group HR/Payroll Companies
Centralized HR/payroll companies are frequently used by MNE groups but raise specific issues in relation to the Pillar Two GloBE Rules. In particular, the impact of using a centralized function and the nature of recharges could have an impact on the substance-based income exclusion of group entities.
Territorial Tax Systems and Pillar Two
Jurisdictions that apply a territorial basis do not tax foreign source income. This raises some interesting issues in the application of the Pillar 2 rules.
Gibraltar Issues Simplification Measure for MNEs to Simplify Global Minimum Tax Compliance
On February 20, 2025, Gibraltar issued the Income Tax (Allowances, Deductions, and Exemptions) (Amendment) Rules 2025 to allow in-scope MNEs to just be taxed under the Global Minimum Tax Act, and not the Income Tax Act.
Interaction Between Bonus Depreciation and the Substance-Based Income Exclusion
In this article we look at the interaction between deferred tax on bonus depreciation and the substance-based income exclusion on investments in tangible assets.
French 2025 Finance Act Includes Pillar 2 Changes for OECD Administrative Guidance
On February 15, 2025, Law 2025-127 of February 15, 2025 (the 2025 Finance Act) was published in the French Official Gazette. This includes a number of amendments to the Pillar 2 regime from December 31, 2024.
Pillar Two: Trusts & Foundations
The Pillar Two rules don’t just apply to companies. They apply to ‘entities’. This means that the Pillar Two GloBE rules can apply to both trusts and foundations.
Pension Funds & Pillar Two
Pension funds are subject to a number of specific provisions under the Pillar Two rules. In this article we look at some of the key aspects of Pillar Two that impact on Pension Funds.
Poland Issues a List of Jurisdictions that Have Qualified IIRs and DMTTs for Pillar 2
On February 12, 2025, Poland issued 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).
Practical Implications of Pillar 2 Compliance after the January 2025 OECD Guidance
In January 2025, the OECD provided some much-needed guidance on the operation of the Pillar 2 GloBE rules. This Orbitax article provides an analysis of the impact of the guidance on Pillar 2 compliance.
