The Substance-Based Income Exclusion & Low Profit Margin Companies
The substance-based income exclusion favours capital intensive and certain low profit margin companies. These companies stand to benefit the most.
The substance-based income exclusion favours capital intensive and certain low profit margin companies. These companies stand to benefit the most.
On March 6, 2024, the Belgian Government submitted a draft law to Parliament which includes provisions to amend the GloBE Law to implement aspects of the OECD Administrative Guidance.
On March 7, 2024, the Australian Taxation Office provided an update on the implementation of Pillar Two.
Analysis of the implementation of the Pillar Two Global Minimum Tax rules in the UK on or after 31 December 2023. Updated for the 2024 Finance Act.
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.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Thailand for accounting periods beginning on or after January 1, 2025. Updated for the Draft Law issued on March 1, 2024.
On March 1, 2024, the Thai Revenue Department published an 18-page consultation paper on the implementation of Pillar Two. This includes draft legislation which includes, an IIR, UTPR and a domestic minimum tax.
In this article, we look at the status of Pillar Two implementation in the EU, as at March 1, 2024, for jurisdictions that have not yet enacted domestic law to implement the EU Minimum Tax Directive.
Updates to our ‘OECD Administrative Guidance: Domestic Implementation Matrix’ to reflect the latest Pillar 2 laws for Greece and South Africa.
On February 22, 2024, the UK enacted the 2024 Finance Act to domestically implement amendments provided in the OECD Administrative Guidance.
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