Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Bahrain for accounting periods beginning on or after January 1, 2025. Updated for Decree-Law No. (11) of 2024 issued on September 1, 2024.
On September 4, 2024, the Swiss Federal Council announced that the Income Inclusion Rule (IIR) will apply from January 1, 2025.
The substance-based income exclusion favours capital intensive and certain low profit margin companies. These companies stand to benefit the most.
Whilst the treatment of investment property for financial accounting purposes is important when determining the GloBE treatment, of even more importance are any differences between the financial accounting treatment and the domestic tax treatment.
On August 20, 2024, the German Ministry of Finance issued a Discussion Draft of a Draft Law to implement most aspects of the Third Set of OECD Administrative Guidance.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in The Bahamas for accounting periods beginning on or after January 1, 2025. Updated for the draft legislation issued by The Bahamas Government on August 12, 2024.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Jersey for accounting periods beginning on or after January 1, 2025. Updated for the draft legislation issued on August 14, 2024.
Updated Pillar 2 GloBE guide for Austria following OECD Administrative Guidance, including currency provisions and extending the Transitional CbCR Safe Harbour to cases where an MNE is not required to prepare CbC
On August 12, 2024, the Finnish government issued draft legislation to amend the Minimum Tax Act to reflect numerous aspects of the OECD Administrative Guidance. The draft law is subject to a consultation until September 6, 2024, and once enacted will apply from January 1, 2024.
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 August 8, 2024, the Bermuda Ministry of Finance issued a consultation on the administrative provisions for the new corporate income tax that is to apply from 2025
The clarifications and additions to the Commentary to the Pillar Two GloBE Rules provided by the OECDs Administrative and Safe Harbours Guidance, means that there are now up to four jurisdictional effective tax rates (ETRs) that may need to be calculated to determine the impact of the GloBE Rules.
Updates to our ‘OECD Administrative Guidance: Domestic Implementation Matrix’ to reflect the latest Pillar 2 laws for Portugal and Turkey
The “Law on the Amendment of Tax Laws and Certain Laws” was published in the Turkish Official Gazette on August 2, 2024. Articles 37 – 50 of the Law include provisions to implement the GloBE rules in domestic law from January 1, 2024. This includes the IIR, UTPR and a domestic minimum top-up tax.
On July 25, 2024, the Ministry of Economy and Finance issued the 2024 Tax Law Amendment Bill. This includes a number of amendments to the South Korean global minimum tax law to reflect aspects of the OECD Administrative Guidance.
On July 29, 2024, the UK government issued draft legislation for the implementation of the Pillar Two anti-avoidance rules targeting Hybrid Arbitrage Arrangements.
On July 29, 2024, the Israeli Ministry of Finance announced it will implement a QDMTT from January 1, 2026. The IIR and UTPR will not be introduced at that point and further consideration will be given to their implementation after a review of the effectiveness of the QDMTT.
On June 11, 2024, Law No. 684 was published in the Danish Official Gazette. This implements additional aspects of the OECD Administrative Guidance.
English Translation Turkey’s draft Global Minimum Tax Law
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Turkey for accounting periods beginning on or after January 1, 2024. Updated for the draft legislation submitted to the Turkish Parliament on July 16, 2024.
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