Many jurisdictions will require GloBE registration for administrative purposes, however, the law issued to date has been inconsistent. We outline the GloBE registration obligations from the domestic legislation (enacted and draft) issued to date, with citations and links to relevant laws.
On 10 October 2024, the French Government presented the draft Finance Bill for 2025 to Parliament. This includes amendments to its General Tax Code to reflect the OECD Administrative Guidance, including the December 2023 OECD amendments to the Safe Harbours.
On January 9, 2025, Liechtenstein released its GloBE Registration form (submitted via email within 6 months of the end of the fiscal year).
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.
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