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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The Pillar Two rules include specific rules for Joint Ventures (JVs) that would otherwise not be within the scope of Pillar Two due to not being consolidated in the financial accounts of the MNE group. However, of more interest is how the amount of top-tax tax (and by implication the amount not collected) varies depending on the JV group structure. Read more in this article.
MNE groups should pay careful attention to any group financing companies in light of the Pillar Two Rules. In this analysis we look at the impact of Pillar Two under for both general GloBE and QDMTT purposes.
On March 22, 2024, the Decree of the Ministry of Economy and Finance No. 1048, to amend the Enforcement Regulations of the International Tax Adjustment Act entered into force.
On March 22, 2024, the Enforcement Regulations to the International Tax Adjustment Act were amended. This includes attachments for the GIR (in English and Korean), the GloBE Tax Return and the Notification Form for a Foreign CE to File the GIR.
Whilst the OECD Model Rules require the application of the IIR to Low-Taxed Constituent Entities outside the jurisdiction, the Commentary permits the application of the IIR domestically (a ‘DIIR’). Both New Zealand and the EU apply a DIIR.
Analysis of the Pillar Two GloBE rules in Greece – updated for Law 5100/2024 of April 5, 2024 implementing the EU Minimum tax Directive.
On April 5, 2024, Law 5100/2024 was published in the Official Gazette. This implements the EU Minimum Tax Directive in Greece from December 31, 2023 (with the UTPR applying from December 31, 2024).
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Liechtenstein from 2024. Updated for the GloBE Regulation of March 28, 2024.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in New Zealand. Updated for the enacted legislation on March 28, 2024.
On March 28, 2024, the Decree on the minimum taxation of large groups of undertakings (the ‘GloBE Regulation’) was published in the Official Gazette.
On March 28, 2024, the GloBE Regulations were published in the Liechtenstein Official Gazette and New Zealand’s Pillar Two Law received Royal Assent.
The definition of CFC taxes that are restricted in the GloBE rules is much narrower than under many domestic CFC regimes. In this article we look at this issue.
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