QDMTT Legislative Tracker: Updated to March 28, 2024
Updates to our QDMTT Legislative Tracker to include domestic QDMTT legislation released up to March 28, 2024.
As with most aspects of the GloBE Rules, Article 6.3.1 of the OECD Model Rules provides that the GloBE treatment of intra-group transfers of assets follows the accounting treatment.
The accounting treatment generally values the transfer of assets at fair value (eg FRS 102 requires the total fair value of any consideration as well as the assets, liabilities and contingent liabilities of the acquirer to be determined).
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As with most aspects of the GloBE Rules, Article 6.3.1 of the OECD Model Rules provides that the GloBE treatment of intra-group transfers of assets follows the accounting treatment.
The accounting treatment generally values the transfer of assets at fair value (eg FRS 102 requires the total fair value of any consideration as well as the assets, liabilities and contingent liabilities of the acquirer to be determined).
Given many domestic tax regimes permit gains and losses to be deferred on intra-group transfers, Article 6.3.2 of the OECD Model Rules include a similar rule which applies where there is a ‘GloBE Reorganisation’.
A Globe Reorganisation occurs where there is a transfer of assets and:
(a) the consideration for the transfer is, in whole or in significant part, equity interests
(b) the transferors gain or loss on the assets is not wholly or partly subject to tax; and
(c) the tax law applicable to the transferee entity requires them to use the transferor’s tax base as the carrying value of the assets (the so-called ‘stand in the shoes’ principle).
Updates to our QDMTT Legislative Tracker to include domestic QDMTT legislation released up to March 28, 2024.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Australia for accounting periods beginning on or after January 1, 2024. Updated for the draft legislation issued by the Australian Treasury on March 21, 2024.
On March 19, 2024, the Swedish Ministry of Finance issued a proposal (including Draft Legislation and Explanatory Notes) to amend its Pillar Two law to include relevant provisions of the OECD Administrative Guidance.
On March 21, 2024, the Australian Treasury issued draft GloBE legislation for consultation. The consultation is open until April 16, 2024.
On March 13, 2024, the Lithuanian Parliament updated the draft law to implement the EU Minimum Tax Directive.
On March 11, 2024, the Finance and Expenditure Committee of the New Zealand Parliament made a number of amendments to the Taxation (Annual Rates for 2023–24, Multinational Tax, and Remedial Matters) Bill (which includes proposed legislation to transpose the OECD GloBE Rules).
On March 15, 2024, the UAE launched a public consultation on the implementation of the GloBE rules in the UAE. The consultation is open until April 10, 2024.
On March 14, 2024, the UK Government confirmed it is to apply an anti-avoidance rule for the purposes of the Transitional CbcR Safe Harbour from March 14, 2024.
We track the implementation of key aspects of the Transitional CbCR Safe Harbour in draft and enacted domestic laws issued to date back to the OECD Safe Harbours Guidance and the OECD Administrative Guidance.
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