UK to Apply Transitional CbCR Safe Harbour Anti-Avoidance Rule From March 14, 2024
On March 14, 2024, the UK Government confirmed it is to apply an anti-avoidance rule for the purposes of the Transitional CbcR Safe Harbour from March 14, 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 March 14, 2024, the UK Government confirmed it is to apply an anti-avoidance rule for the purposes of the Transitional CbcR Safe Harbour from March 14, 2024.
We track the implementation of key aspects of the Transitional CbCR Safe Harbour in draft and enacted domestic laws issued to date back to the OECD Safe Harbours Guidance and the OECD Administrative Guidance.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Belgium for accounting periods beginning on or after December 31, 2023. Updated for the Draft Law to amend the ‘Act on the introduction of a minimum tax for multinational enterprise groups and large domestic groups’ of March 6, 2024.
The substance-based income exclusion favours capital intensive and certain low profit margin companies. These companies stand to benefit the most.
English Translation of the Belgian Draft Global Minimum Tax Amendment Law
On March 6, 2024, the Belgian Government submitted a draft law to Parliament which includes provisions to amend the GloBE Law to implement aspects of the OECD Administrative Guidance.
On March 7, 2024, the Australian Taxation Office provided an update on the implementation of Pillar Two.
Analysis of the implementation of the Pillar Two Global Minimum Tax rules in the UK on or after 31 December 2023. Updated for the 2024 Finance Act.
Updates to our QDMTT Legislative Tracker to include domestic QDMTT legislation released up to March 6, 2024.
In most cases, a Qualifying Refundable Tax Credit will result in a higher Pillar Two effective tax rate than a non-qualifying tax credit. However, this is not always the case. We look at some examples in this article.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Thailand for accounting periods beginning on or after January 1, 2025. Updated for the Draft Law issued on March 1, 2024.
On March 1, 2024, the Thai Revenue Department published an 18-page consultation paper on the implementation of Pillar Two. This includes draft legislation which includes, an IIR, UTPR and a domestic minimum tax.
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