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QDMTT Legislative Tracker

QDMTT: Legislative Tracker

Track the development and application of QDMTTs as they are implemented globally. The OECD Administrative Guidance provides significant flexibility as to their design.

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GloBE Country Guide: Switzerland

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.

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commercial property

Investment Property & The GloBE Rules

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.

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Joint Ventures and Pillar Two

Joint Ventures and the Allocation of Pillar Two Top-Up Tax

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.

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image showing the world with flags in certain places to illustrate permanent establishments under pillar two

Domestic Implementation of the GloBE Rules: Differing Approaches

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.

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