GloBE Country Guide: Sweden
March 17, 2023
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Sweden from January 1, 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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Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Sweden from January 1, 2024.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Switzerland from January 1, 2024.
In today’s 2023 Spring Budget, the UK government confirmed that it will include the Pillar Two Global Minimum Tax in the Spring Finance Bill 2023.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in the United Kingdom from January 1, 2024.
Last week, the Vietnamese Government released Resolution 31/NQ-CP of the February 2023, Regular Government Session to speed-up Global Minimum Tax implementation.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in the Netherlands from January 1, 2024.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in South Korea from January 1, 2024.
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.
Hungary’s Prime Minister Viktor Orbán reiterated that Hungary has an Official letter from the EU agreeing to the Local Business Tax being a covered tax for the purposes of the Pillar Two Global Minimum Tax.
On March 6, 2023, Spain’s Ministry of Finance and Public Function opened a public consultation on the transposition into Spanish law of the European Directive on the Global Minimum Tax
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.
Yesterday, the Thai Cabinet approved the proposal to implement a Global Minimum Tax (see item 48 of the following Cabinet Resolution:
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