In Bermuda’s 2023 Budget last week, the government has announced it is actively looking at how to implement the Pillar Two global minimum tax and that Bermuda could reap significant revenue benefits.
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Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Bahrain for accounting periods beginning on or after January 1, 2025. Updated for Decree-Law No. (11) of 2024 issued on September 1, 2024.
On September 4, 2024, the Swiss Federal Council announced that the Income Inclusion Rule (IIR) will apply from January 1, 2025.
The substance-based income exclusion favours capital intensive and certain low profit margin companies. These companies stand to benefit the most.
Whilst the treatment of investment property for financial accounting purposes is important when determining the GloBE treatment, of even more importance are any differences between the financial accounting treatment and the domestic tax treatment.
On August 20, 2024, the German Ministry of Finance issued a Discussion Draft of a Draft Law to implement most aspects of the Third Set of OECD Administrative Guidance.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in The Bahamas for accounting periods beginning on or after January 1, 2025. Updated for the draft legislation issued by The Bahamas Government on August 12, 2024.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Jersey for accounting periods beginning on or after January 1, 2025. Updated for the draft legislation issued on August 14, 2024.
Updated Pillar 2 GloBE guide for Austria following OECD Administrative Guidance, including currency provisions and extending the Transitional CbCR Safe Harbour to cases where an MNE is not required to prepare CbC
On August 12, 2024, the Finnish government issued draft legislation to amend the Minimum Tax Act to reflect numerous aspects of the OECD Administrative Guidance. The draft law is subject to a consultation until September 6, 2024, and once enacted will apply from January 1, 2024.
MNE groups should pay careful attention to any group financing companies in light of the Pillar Two Rules. In this analysis we look at the impact of Pillar Two under for both general GloBE and QDMTT purposes.
On August 8, 2024, the Bermuda Ministry of Finance issued a consultation on the administrative provisions for the new corporate income tax that is to apply from 2025
The clarifications and additions to the Commentary to the Pillar Two GloBE Rules provided by the OECDs Administrative and Safe Harbours Guidance, means that there are now up to four jurisdictional effective tax rates (ETRs) that may need to be calculated to determine the impact of the GloBE Rules.
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