On December 31, 2024, Law No. 20612, was published to amend the International Tax Adjustment Act for the 2025 Tax Reform provisions. This includes some amendments to the Global Minimum Tax provisions.
On December 31, 2024, Ministerial Decree of December 27, 2024 was published in the Official Gazette. This implements Article 4.1-4.3 of the February 2023 OECD Administrative Guidance and some aspects of the June 2024 OECD Administrative Guidance on deferred taxation.
The Ministerial Decree of December 27, 2024 published in the Official Gazette on December 31, 2024 provides for a number of miscellaneous, but important aspects of the OECD Administrative Guidance that were not included in the original Minimum Tax Law.
The Dutch Minimum Tax Executive Decree 2024 was published in the Government Gazette on December 23, 2024 to implement various aspects of the OECD Administrative Guidance.
On December 26, 2024, The Emergency Decree on Top-Up Tax B.E. 2567, was published in the Government Gazette to implement the Pillar 2 GloBE rules from January 1, 2025.
On December 27, 2024, the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024 was published in the Official Gazette. The Bill includes an Income Inclusion Rule (IIR) and a domestic minimum tax from January 1, 2025.
On December 31, 2024, Oman issued Royal Decree No. 70/2024 to implement the Pillar 2 Income Inclusion Rule and a Domestic Minimum Tax from January 1, 2025..
On December 20, 2024, Curacao’s Global Minimum Tax Ordinancewas approved by Parliament and it was subsequently published on December 27, 2024.
On December 30, 2024, Singapore published the Multinational Enterprise (Minimum Tax) Regulations 2024 which provide for the detailed rules for the application of the multinational top-up tax and domestic top-up tax.
On December 30, 2024, Brazil’s President enacted Law No. 15,079, of December 27, 2024 that repeats (with minor amendments) Provisional Measure No. 1,262, of October 3, 2024, to introduce a Domestic Minimum Tax (DMT) from January 1, 2025.
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