Belgium Issues a Draft 7 Page QDMTT Return for Consultation
October 21, 2024
On October 18, 2024, Belgium issued a draft 7-page QDMTT Return for consultation. The consultation lasts until November 8, 2024.
Paraguay stands out amongst most South American countries as being the one most at risk of substantial jurisdictional top-up tax for in-scope groups under Pillar Two.
Its standard rate of corporate income tax is 10% under Article 21 of Law No. 6,380/19 on the Modernization and Simplification of the National Tax System. This is in contrast to other South American jurisdictions that have much higher standard rates of corporate income tax, such as:
Brazil – 34%
Argentina – 35%
Chile – 27%
Peru – 29.5%
Columbia – 35%
Venezuela – 34%
Guyana – 40%
Mexico – 30%
Nicaragua – 30%
Ecuador – 25%
Bolivia – 25%
Uruguay – 25%
Article 1 of Law No. 6,380/19 on the Modernization and Simplification of the National Tax System establishes a territorial basis for corporate income tax in Paraguay. As such, only income from Paraguayan sources is taxable, subject to a number of exceptions. For instance, Article 6 of Law 6,380/19 provides that Paraguayan source income includes:
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On October 18, 2024, Belgium issued a draft 7-page QDMTT Return for consultation. The consultation lasts until November 8, 2024.
On October 10, 2024, Ireland published its 2024 Finance Bill. In the Bill, a number of amendments are made to the Global Minimum Tax provisions. Our Ireland GloBE Country Guide has been updated for relevant changes.
On October 18, 2024, Portugal introduced the EU Minimum Tax Directive into domestic legislation, whilst on October 16, 2024 and October 18, 2024 (respectively), the Bahamas and Cyprus tabled legislation in Parliament to implement Pillar Two.
The Pillar Two effective tax rate (ETR) calculation for investment entities is similar to the standard ETR calculation, however, there is an important twist in that the top-up tax is adjusted for minority interests. There is no adjustment for minority interests under the standard ETR calculation. In this article we look at the impact of this.
On October 10, 2024, Ireland published its 2024 Finance Bill. In the Bill, a number of amendments are made to the Global Minimum Tax provisions.
Top-up taxes under a QDMTT are added to covered taxes of a CFC but only for the purposes of calculating the allocation of Blended CFC Taxes. The way the rules operate is aimed at minimising unrelievable CFC taxes under Blended CFC Regimes. Read more.
Updates to our ‘OECD Administrative Guidance: Domestic Implementation Matrix’ to reflect the latest Pillar 2 updates for Brazil.
On October 4, 2024, Singapore issued a Consultation document on the GloBE Safe Harbours (Transitional Country-by-Country Reporting (“CbCR”) Safe Harbour, QDMTT Safe Harbour and the Simplified Calculations Safe Harbour), as well as other aspects of the OECD Administrative Guidance.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Brazil for accounting periods beginning on or after January 1, 2025. Updated for Provisional Measure No. 1,262, and Normative Instruction No. 2,228 of October 3, 2024.
Yesterday, Brazil issued Provisional Measure No. 1,262, of October 3, 2024 and a supporting Regulation to introduce a Domestic Minimum Tax (intended to be a QDMTT) from January 1, 2025. It now needs to be ratified by Congress.
Our Lithuania GloBE Guide has been updated for the Order on Information Notices in relation to Pillar Two.
On September 18, 2024, the Bulgarian Ministry of Finance published draft legislation for public consultation to amend the Bulgarian minimum taxation rules, including the introduction of the Transitional UTPR Safe Harbour.
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