Global Minimum Tax
In Today’s 2023 Budget, Hong Kong’s Financial Secretary confirmed that Hong Kong will implement the Pillar Two Global Minimum Tax from 2025.
They estimate that it will generate tax revenue of $15 billion per year for the Government. A consultation is to be launched to allow MNE groups to make early preparation.
It was also announced that Hong Kong will be introducing a Patent Box.
Given the significant foreign direct investment (FDI) into Hong Kong (in 2021 FDI inflows into Hong Kong were US$140.7 billion, the 3rd highest globally behind the United States and Mainland China), it is expected that there will be other ancillary adjustments over the next 2 years to the domestic tax regime to ensure Hong Kong remains internationally competitive after the GloBE rules are introduced.
If you haven’t got a subscription you can join up below.
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.
Updates to our ‘OECD Administrative Guidance: Domestic Implementation Matrix’ to reflect the latest Pillar 2 updates for Brazil.
On October 4, 2024, Singapore issued a Consultation document on the GloBE Safe Harbours (Transitional Country-by-Country Reporting (“CbCR”) Safe Harbour, QDMTT Safe Harbour and the Simplified Calculations Safe Harbour), as well as other aspects of the OECD Administrative Guidance.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Brazil for accounting periods beginning on or after January 1, 2025. Updated for Provisional Measure No. 1,262, and Normative Instruction No. 2,228 of October 3, 2024.
Yesterday, Brazil issued Provisional Measure No. 1,262, of October 3, 2024 and a supporting Regulation to introduce a Domestic Minimum Tax (intended to be a QDMTT) from January 1, 2025. It now needs to be ratified by Congress.
Our Lithuania GloBE Guide has been updated for the Order on Information Notices in relation to Pillar Two.
On September 18, 2024, the Bulgarian Ministry of Finance published draft legislation for public consultation to amend the Bulgarian minimum taxation rules, including the introduction of the Transitional UTPR Safe Harbour.
On September 24, 2024, the Puerto Rico Treasury Department launched a public consultation on the implementation of the GloBE rules, including a QDMTT.
On September 11, 2024, the government of Slovakia approved a draft bill on amendments to the law to reflect various aspects of the OECD Administrative Guidance. See our updated GloBE Guide.
On September 17, 2024, a draft law to amend the Minimum Tax Act was published. This includes a number of amendments to implement the OECD Administrative Guidance. Read our updated GloBE Country Guide.
On September 19, 2024, the OECD held the signing ceremony for the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule. 9 jurisdictions have signed with a further 10 stating an intention to sign.
On April 3, 2024, Regulations for the implementation of the GloBE law were issued which implement a number of aspects of the First, Second and Third Set of OECD Administrative Guidance. The Regulations were amended in August 2024.
This website is not affiliated with or related to the OECD. We provide independent insights and analysis on the OECD Two-Pillar Solution
© 2024 OECDPillars
All Rights Reserved
