Track the development and application of QDMTTs as they are implemented globally. The OECD Administrative Guidance provides significant flexibility as to their design.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Switzerland from January 1, 2024. Updated for the Second Draft Decree of May 24, 2023.
It was reported last week that the Vietnamese Ministry of Planning and Investment is working on designing tax incentives to take account of the upcoming application of Pillar Two.
Last week the Bahamian government released a Green Paper asking for feedback on four proposed strategies for the introduction of corporate income tax in the Bahamas, including a QDMTT.
Yesterday, Switzerland issued an updated Draft Decree for the Pillar Two Global Minimum Tax. This follows the previous Draft Decree that was subject to a public consultation.
Whilst both jurisdictions are opting for direct transposition of the OECD Model Rules, there is a key difference in how they are drafted.
Today, the IASB issued the amendments to IAS 12 to take account of the Pillar Two GloBE Rules.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in New Zealand.
Yesterday, New Zealand published a draft law (the Taxation (Annual Rates for 2023–24, Multinational Tax, and Remedial Matters) Bill) to implement the Pillar Two Global Minimum Tax.
On May 13, 2023, the G7 finance ministers reaffirmed their commitment to both Pillars One and Two.
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.
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.
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.
The Pillar Two GloBE treatment of corporate investments will depend to a large extent on the nature of the activities, the accounting treatment and the ownership interest.
In todays’ Budget speech, the Australian Government confirmed it will introduce an Income Inclusion Rule, Under-Taxed Profits Rule and a Domestic Minimum Tax.
The OECD Administrative Guidance includes a number of specific provisions on the design of a domestic minimum tax to ensure it is a QDMTT. In this article we review the UK’s domestic top-up tax based on the OECD Guidance.
An article by article analysis that sources all of the articles of the Japanese Pillar Two law back to the OECD Model Rules, including notes where there are differences from the provisions in the Model Rules.
A number of jurisdictions have issued legislation (either draft or enacted) to implement the Pillar Two GloBE Rules, however, the approach taken differs significantly. In this article we look at domestic differences not only from the OECD Model Rules, but differences in the implementation of the rules between jurisdictions.
The substance-based income exclusion favours capital intensive and certain low profit margin companies. These companies stand to benefit the most.
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