Pillar Two – Domestic Implementation

Following the approval of the EU Global Minimum Tax Directive, Taiwan’s Ministry of Finance has stated it will prepare draft legislation for the government to increase Taiwan’s domestic minimum tax rate from 12% to 15%.
However, this creates a number of issues in terms of its interaction with the Pillar Two global minimum tax.

Liechtenstein has announced it is to issue a consultation on a Pillar Two Global Minimum Tax in March 2023.

In this article, we look at the potential impact of the Pillar Two GloBE Rules for MNEs operating in the Philippines. 

On December 20, 2022, Indonesia issued Government Regulation No. 55/2022 on the Adjustment of Regulations in the Field of Income Tax. This included reference to the implementation of a global minimum tax in Indonesia as well a a desire to implement Pillar One.

Today’s OECD webinar on Tax challenges of digitalisation: Economic impact assessment of the Two-Pillar Solution reported that revenue gains from both Pillar One and Pillar Two is expected to increase from the previous economic impact assessment. 

With the enactment of the Pillar Two GloBE Rules in South Korea from January 1, 2024, the costs of an unintentional permanent establishment (PE) in South Korea may be significantly greater. 

As a members only resource, we include an unofficial English translation of the South Korean Global Minimum Tax Law (Law 19191 of December 31, 2022).

On December 31, 2022 the first domestic law was enacted to give effect to the Pillar Two GloBE rules from January 1, 2024. Read more.

The African Tax Administration Forum (ATAF) has released a Suggested Approach to Drafting Domestic Minimum Top-Up Tax Legislation under the Pillar Two GloBE Rules.