QDMTT Legislative Tracker Updated for Latest Administrative Guidance
We have updated our QDMTT Legislative Tracker to include details of the amendments to the design of QDMTTs in the July 2023 Administrative Guidance.
We have updated our QDMTT Legislative Tracker to include details of the amendments to the design of QDMTTs in the July 2023 Administrative Guidance.
The Second Set of OECD Administrative Guidance includes a number of additions to the design features of a QDMTT. Read more in this article.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in the Netherlands from December 31, 2023. Updated for the Minimum Tax Bill of May 31, 2023.
Track the development and application of QDMTTs as they are implemented globally. The OECD Administrative Guidance provides significant flexibility as to their design.
Top-up taxes under a QDMTT are added to covered taxes of a CFC but only for the purposes of calculating the allocation of Blended CFC Taxes. The way the rules operate is aimed at minimising unrelievable CFC taxes under Blended CFC Regimes. Read more.
The clarifications and additions to the Commentary to the Pillar Two GloBE Rules provided by the OECDs Administrative and Safe Harbours Guidance, means that there are now up to four jurisdictional effective tax rates (ETRs) that may need to be calculated to determine the impact of the GloBE Rules.
Under Article 4.3.2(c) of the OECD Model Rules, tax paid under a CFC regime is generally allocated for GloBE purposes to the CFC entity. However, Article 5.1.3 of the OECD Administrative Guidance confirms that this is not the case for Qualified Domestic Minimum Top-Up Taxes (QDMTTs).
Qualifying Domestic Minimum Top-Up Taxes (QDMTT’s) are a key part of the top-up tax calculation. Jurisdictions are free to introduce them or not and they are taken into account when calculating jurisdictional top-up tax. In this article we look at why a domestic minimum tax would need to be set at above 15% if it was not a qualifying domestic minimum top-up tax.
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