The Impact of the Different ETR Calculation for Investment Funds
The Pillar Two effective tax rate (ETR) calculation for investment entities is similar to the standard ETR calculation, however, there is an important twist in that the top-up tax is adjusted for minority interests. There is no adjustment for minority interests under the standard ETR calculation. In this article we look at the impact of this.
Foreign Tax Credits and the Pillar Two GloBE Rules
Foreign tax credits interact with the Pillar Two GloBE Rules in a number of ways. In this article we assess the key impact.
When is a Qualifying Refundable Tax Credit Not Beneficial?
In most cases, a Qualifying Refundable Tax Credit will result in a higher Pillar Two effective tax rate than a non-qualifying tax credit. However, this is not always the case. We look at some examples in this article.
Romania Issues Final Pillar 2 Form for Nominating a DMTT Filing Entity
On July 9, 2025, ANAF Order 1.729/2025 was issued to nominate a single designated entity for QDMTT filing and payment purposes, if there are several constituent entities in Romania that are part of the same group.
Japan Issues Updated GloBE Information Return
On June 30, 2025, Japan issued its updated GloBE Information Return (GIR) to reflect the OECD GIR changes in January 2025.
Kuwait Issues Executive Regulations for its Domestic Minimum Tax
The Executive Regulations were issued on June 29, 2025, in Ministerial Resolution No. 55 of 2025. The Regulations provide for the detailed rules for the application of the domestic minimum top-up tax from January 1, 2025.
Hungary Extends Pillar 2 Registration Deadline in 2025 Spring Tax Package
Section 26 of the amendment law in the 2025 Spring Tax Package (approved on June 19, 2025), amends the registration deadline to the last day of the second month following the last day of the tax year.
Isle of Man Issues Updated Global Minimum Tax Order
On June 19, 2025, the updated version of the Global Minimum Tax (Pillar Two) Order 2024 was published.
Romania Issues a Draft Pillar 2 Form for Nominating a Filing Entity
On June 20, 2025, a draft Order was issued to nominate a single designated entity for QDMTT filing and payment purposes, if there are several constituent entities in Romania that are part of the same group.
Norway Opens a Consultation to Implement June 2024 and January 2025 OECD Administrative Guidance
On June 16, 2025, the Norwegian Ministry of Finance opened a consultation on a Draft Bill to amend the Norwegian Minimum Tax Act for the June 2024 and January 2025 OECD Administrative Guidance.
