Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Barbados for accounting periods beginning on or after January 1, 2024. Updated for the draft legislation being considered by the Barbadian Parliament.
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.
The GloBE rules include a number of insurance specific adjustments. In this article we look at the nature of these provisions as well as the impact of the GloBE rules on insurance companies generally. Updated for OECD Administrative Guidance.
Updates to our QDMTT Legislative Tracker to include domestic QDMTT legislation released up to March 28, 2024.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Australia for accounting periods beginning on or after January 1, 2024. Updated for the draft legislation issued by the Australian Treasury on March 21, 2024.
On March 19, 2024, the Swedish Ministry of Finance issued a proposal (including Draft Legislation and Explanatory Notes) to amend its Pillar Two law to include relevant provisions of the OECD Administrative Guidance.
On March 21, 2024, the Australian Treasury issued draft GloBE legislation for consultation. The consultation is open until April 16, 2024.
On March 13, 2024, the Lithuanian Parliament updated the draft law to implement the EU Minimum Tax Directive.
On March 11, 2024, the Finance and Expenditure Committee of the New Zealand Parliament made a number of amendments to the Taxation (Annual Rates for 2023–24, Multinational Tax, and Remedial Matters) Bill (which includes proposed legislation to transpose the OECD GloBE Rules).
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