Countries With Pillar 2 Provisions for Securitisation Entities
The Fourth Set of OECD Administrative Guidance (issued on June 17, 2024) includes guidance on the treatment of Securitization Entities.
The Fourth Set of OECD Administrative Guidance (issued on June 17, 2024) includes guidance on the treatment of Securitization Entities.
On May 24, 2024, the Corporation Top-up Tax Act, 2024 was published in the Official Gazette. This implements a domestic minimum top-up tax intended to be a QDMTT for Pillar 2 purposes.
On November 29, 2024, the Domestic Minimum Top-Up Tax Act, 2024 was published in the Official Gazette of The Bahamas. This implements a domestic minimum top-up tax intended to be a QDMTT for Pillar 2 purposes.
On December 19, 2024, Law 917/2024 was published in the Finnish Official Gazette to amend the Minimum Tax Act to reflect numerous aspects of the OECD Administrative Guidance. This applies to financial years beginning on or after January 1, 2024.
On December 18, 2024, Cyprus published the law to implement the EU Minimum Tax Directive its its Official Gazette. This implements the IIR from December 31, 2023 and a UTPR and domestic minimum tax from December 31, 2024.
On December 31, 2024 the Indonesian Ministry of Finance issued Minister of Finance Regulation Number 136 of 2024 (the ‘Regulation’) for the imposition of a global minimum, tax which will take effect from January 1, 2025.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Australia for accounting periods beginning on or after January 1, 2025. Updated for the Regulation issued by the Ministry of Finance on December 31, 2024.
On December 23, 2024, Australia issued the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024 (the ‘Rules’) to provide for the detailed application of the Pillar 2 GloBE rules in Australia.
On January 3, 2025 the Law on Global Minimum Corporate Income Tax was published in the Official Gazette to implement the EU Global Minimum Tax Directive.
On January 15, 2025, the OECD issued a list of jurisdictions that have transitional qualified status, further Administrative Guidance on the application of the Article 9.1 transitional rules, and an updated GloBE Information Return and GIR XML Schema, as well as the GIR MCAA.
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