QDMTT: Legislative Tracker
May 31, 2023
Track the development and application of QDMTTs as they are implemented globally. The OECD Administrative Guidance provides significant flexibility as to their design.
Cloud-based software for advanced Pillar Two analytics and insights.
Our Pillar Two Tax Engine allows you to model the impact of the Pillar Two GloBE Rules and any top-up tax liability, determine best and worst-case scenarios and simulate the impact of making various GloBE elections.
Our Pillar One Modelling Tool provides a calculation of the estimated profits reallocated to jurisdictions under Amount A of Pillar One and the estimated corporate income tax on those reallocated profits.
Given Pillar One feeds directly into Pillar Two, it also estimates the Pillar Two top-up tax liability after the application of Pillar One.
Free access for site members.
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.
An article by article analysis that sources all of the articles of the South Korean Pillar Two law back to the OECD Model Rules, including notes where there are differences from the provisions in the Model Rules.
In this article, we map, on an Article-by-Article basis, the EU Directive to the OECD Model Rules and identify provisions in the EU Directive which have no equivalent in the Model Rules.
The German Federal Ministry of Justice has proposed a Pillar 2 “white list” for countries whose nominal tax rate is sufficiently above the 15% global minimum rate.
In this article we look at the interaction between deferred tax on bonus depreciation and the substance-based income exclusion on investments in tangible assets.
Our table sources all of the Articles in the OECD Model Rules to the relevant provision in the UK draft legislation. It also includes notes where there are differences from the provisions in the Model Rules.
In this article we highlight key differences between the UK approach to Excluded Entities in the draft GloBE legislation and the approach taken in the OECD Model Rules.
The UK proposed some minor technical changes to the domestic implementation of the Pillar Two GloBE rules on April 14, 2023.
Nigeria may be reconsidering its approach to Pillar 2 following an April 2023 workshop jointly organised by the OECD and the Federal Inland Revenue Service (FIRS).
Many jurisdictions will require GloBE registration for administrative purposes, however, the law issued to date has been inconsistent. We outline the GloBE registration obligations from the domestic legislation (enacted and draft) issued to date.
Australia issued an Exposure Draft for Multinational Tax Transparency Reporting last week to provide for global public country-by-country reporting for many large multinational enterprises (MNEs) operating in Australia. This includes the GloBE ETR.
For fiscal years that begin on or before 31 December 2025 but not ending after 30 June 2027, the OECD Administrative Guidance includes a simplified formula to allocate CFC taxes in blended CFC regime. Use our simple calculator.
Calculate estimated GloBE top-up tax. Add unlimited companies and jurisdictions via an easy to use control panel to view potential jurisdictional liabilities.
Our Modelling Tool takes the underlying source data from the OECD aggregated CbC source data and subjects it to a data manipulation process to provide a drill down into some of the key metrics and data sources that are relevant for Pillar Two on a jurisdictional basis.
Use our members Income Inclusion Rule Calculator to see how the IIR applies. Enter details of the low-taxed entity including jurisdictional GloBE income and other relevant information to determine top-up tax payable by the parent company.
Our Global Digital Services Tax Tracker has been updated to January 23, 2023.
Our members-only modelling tool carries out the calculations based on the required inputted information to determine whether the Transitional CbCR Safe Harbour applies.
Our Global VAT on Digital Services Tracker has been updated and now covers over 80 jurisdictions.
Use our global assessment tool to determine the VAT position on the provision of international digital services. The tool is fully cited to the relevant domestic law.
Use our Global map to determine the effective tax rate for R&D expenditure globally. Including the average R&D ETR per jurisdiction and the impact of incentives.
Global intellectual property (IP) incentives have grown in recent years. Use our tool to compare different regimes.
This Modelling Tool accompanies our analysis Modelling the Impact of Payroll Tax Incentives Post Pillar 2. Members use this tool to adjust key variables.
The Subject-to-Tax Rule is a key component of Pillar Two, and unlike the GloBE Rules focuses on source jurisdictions. Our members-only global map highlights domestic withholding taxes at less than the 9% rate under the Subject-to-Tax Rule.
For Pillar Two purposes, investments in fixed assets can involve an interaction between deferred tax impacts and the the substance-based income exclusion.
Our interactive map covers the current global treatment of VAT on digital services. Fully cited with links to relevant laws.
Our interactive map breaks down worldwide corporate income tax rates to identify jurisdictions with a headline CIT rate below the Pillar Two 15% rate.
Our Global Digital Services Tax Tracker allows you to stay up to date with international digital service taxes. Cited and with links to domestic legislation.
Our OECD Pillar One Modelling Tool is designed to provide an analysis of the high-level impact of Amount A of Pillar One.
Our Investment Companies Top-Up Tax Calculator models the impact of Pillar Two in a jurisdiction where there are a mix of investment and non-investment companies.
The Revenue Sourcing Rules for Amount A are used to determine where an in-scope multinational group derives its revenues. This is then used in the profit reallocation calculation.
Use our interactive tool to quickly determine the relevant sourcing rule for each revenue type.
Our GloBE Loss Election interactive tool allows you simulate the impact on your top-up tax liability depending on whether a GloBE Loss Election is made or not.
This website is not affiliated with or related to the OECD. We provide independent insights and analysis on the OECD Two-Pillar Solution
© 2023 OECDPillars
All Rights Reserved