Pillar Two – Domestic Implementation

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.

On February 22, 2024, the Ministry of National Economy and Finance issued a draft law to implement the EU Global Minimum Tax Directive. In this article we review the draft law.

On February 21, 2024, the National Treasury and the South African Revenue Service issued the Draft Global Minimum Tax Bill and the Draft Global Minimum Tax Administration Bill.

Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Malta for accounting periods beginning on or after 31 December, 2023. Updated for Legal Notice 32 of 2024 of February 20, 2024.