Belgium Issues a Draft 7 Page QDMTT Return for Consultation
October 21, 2024
On October 18, 2024, Belgium issued a draft 7-page QDMTT Return for consultation. The consultation lasts until November 8, 2024.
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.
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On October 18, 2024, Belgium issued a draft 7-page QDMTT Return for consultation. The consultation lasts until November 8, 2024.
On October 10, 2024, Ireland published its 2024 Finance Bill. In the Bill, a number of amendments are made to the Global Minimum Tax provisions. Our Ireland GloBE Country Guide has been updated for relevant changes.
On October 18, 2024, Portugal introduced the EU Minimum Tax Directive into domestic legislation, whilst on October 16, 2024 and October 18, 2024 (respectively), the Bahamas and Cyprus tabled legislation in Parliament to implement Pillar Two.
The Pillar Two effective tax rate (ETR) calculation for investment entities is similar to the standard ETR calculation, however, there is an important twist in that the top-up tax is adjusted for minority interests. There is no adjustment for minority interests under the standard ETR calculation. In this article we look at the impact of this.
On October 10, 2024, Ireland published its 2024 Finance Bill. In the Bill, a number of amendments are made to the Global Minimum Tax provisions.
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.
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