Foreign Tax Credits and the Pillar Two GloBE Rules
February 21, 2025
Foreign tax credits interact with the Pillar Two GloBE Rules in a number of ways. In this article we assess the key impact.
The Director of International Taxation of the Directorate General of Taxes has confirmed Indonesia is planning to implement the Pillar Two GloBE Rules from 2024.
This is unlike Singapore which has delayed the implementation until 2025.
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Foreign tax credits interact with the Pillar Two GloBE Rules in a number of ways. In this article we assess the key impact.
The Pillar Two rules don’t just apply to companies. They apply to ‘entities’. This means that the Pillar Two GloBE rules can apply to both trusts and foundations.
Pension funds are subject to a number of specific provisions under the Pillar Two rules. In this article we look at some of the key aspects of Pillar Two that impact on Pension Funds.
On February 12, 2025, Poland issued a list of jurisdictions that have qualified status for the purposes of the income inclusion rule and domestic minimum tax (including the QDMTT Safe Harbour).
In January 2025, the OECD provided some much-needed guidance on the operation of the Pillar 2 GloBE rules. This Orbitax article provides an analysis of the impact of the guidance on Pillar 2 compliance.
In this article we look at the implementation of the Pillar 2 Domestic Minimum Tax in the United Arab Emirates, based on Cabinet Decision 142 of 2024 issued on February 8, 2025
In this article we look at the implementation of the Pillar 2 Global Minimum Tax in Germany, including the implementation of the OECD Administrative Guidance.
On February 7, 2025, Order no. 193 of 2025 was published in the Official Gazette. This provides amendments to the income tax return (form 100) to report amounts due under the IIR/UTPR or DMTT.
On February 3, 2025, the Danish Ministry of Finance issued draft legislation (Bill 2024-4606) for consultation. This is to amend the Danish Minimum Tax Act for the June 2024 and January 2025 OECD Administrative Guidance.
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).
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