Impact of the Staggered Implementation of the GloBE Rules

The global implementation of the GloBE rules is staggered with different jurisdictions applying both the Income Inclusion Rule (IIR) and the Under-Taxed Payments Rule (UTPR) from different dates.

Whilst many jurisdictions apply an IIR from 2024,  a number of jurisdictions are to apply an IIR from January 1, 2025. This includes:

-Gibraltar

-Guernsey

-Hong Kong

-Isle of Man

-Jersey

-Malaysia

-Poland

-Singapore

-Switzerland

-Thailand

In addition to this most of the law issued to date delays the application of the UTPR. The EU Directive for instance requires the UTPR to apply for fiscal years beginning from December 31, 2024.

However, the some jurisdictions have not currently legislated for the UTPR at all. This includes:

-Japan;

-Malaysia;

-Norway; and

-Vietnam.

There are therefore significant difference in the application, not only of the IIR, but also potentially the UTPR.