Gibraltar Issues Draft GloBE Law for a DMTT and IIR
On December 10, 2024, Gibraltar issued the Global Minimum Tax Bill 2024 to transpose the OECD Model Rules (and accompanying guidance) into domestic law.
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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On December 10, 2024, Gibraltar issued the Global Minimum Tax Bill 2024 to transpose the OECD Model Rules (and accompanying guidance) into domestic law.
On December 5, 2024, Decree No. 2024-1126 was published in the French Official Gazette. This provides additional details on the reporting requirements for Pillar 2 purposes.
On December 6, 2024 Germany’s Ministry of Finance issued a Second Discussion Draft to implement aspects of the Fourth Set of OECD Administrative Guidance.
In December 2024, updated instructions were provided and the form is now available via the Tax Authority e-services website.
On December 9, 2024, the Kuwaiti Ministry of Finance issued a draft law that includes a 15% domestic minimum top-up tax (DMTT) as part of its overhaul of the Business Profits Tax Regime.
On December 4, 2024, Spain issued a draft decree which includes Regulations for the application of the Global Minimum Tax Law. This is subject to a public consultation.
On November 26, 2024, the Guernsey issued the Income Tax (Approved International Agreements) (Implementation) (OECD Pillar Two GloBE Model Rules) Regulations, 2024 to transpose the OECD Model Rules into domestic Regulations.
On September 18, 2024, the Bulgarian Ministry of Finance published for public consultation draft legislation to amend the Bulgarian minimum taxation rules. This was submitted to Parliament on December 2, 2024.
. On November 12, 2024, the President enacted the Finance Act 2024. In the Act, a number of amendments are implemented to the Global Minimum Tax provisions.
On November 28, the Slovakian Parliament approved the draft GMT amendment law.
On November 15, the Hungarian Tax Authority issued draft forms for the registration notification under Article 44(1) of the Minimum Tax Act, and the appointment of a domestic filing entity under Article 3(47).
On November 27, 2024, the Multinational Enterprise (Minimum Tax) Act 2024 was published in the Singapore Official Gazette. This implements the Pillar 2 GloBE rules in Singapore for fiscal years beginning on or after January 1, 2025.
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