
Spain Issues Regulations for the Global Minimum Tax Act
On April 2, 2025, Spain issued Regulations for the application of the Global Minimum Tax Law. This includes a number of aspects of the OECD Administrative Guidance.
Pension funds are subject to a number of specific provisions under the Pillar Two rules. In this article we look at some of the key aspects of Pillar Two that impact on Pension Funds.
Excluded Entities
Article 1.5.1 of the Model Rules provides that a Pension Fund and certain other related entities are excluded entities for Pillar Two purposes.
This is important as excluded entities are not subject to top-up tax or any obligation to apply an income inclusion rule or under-taxed payments rule. However, excluded entities are still taken into account for the purposes of determining whether the MNE group has exceeded the 750 million consolidated revenue threshold.
• An excluded entity must hold directly or indirectly at least 95% of the value of the entity; and
• The entity must operate ‘exclusively or almost exclusively’ to hold assets or invest funds or carry out activities that are ‘ancillary’ to the activities of the excluded entity.
An entity owned by an excluded entity can also be treated as an excluded entity where at least 85% of the value of an entity is owned (directly or indirectly) by one or more excluded entities (excluding pension services entities), and where substantially all of the entity’s income is dividends or equity gains or losses excluded from the Pillar Two GloBE income or loss calculation.
On April 2, 2025, Spain issued Regulations for the application of the Global Minimum Tax Law. This includes a number of aspects of the OECD Administrative Guidance.
Permanent Establishments (PEs) are subject to a number of specific rules under Pillar Two in order to apply the general provisions to them. Key issues are what is a PE under Pillar Two? where is it located? and how are income and taxes allocated to it?
On March 21, 2025, the UK approved a list of jurisdictions that have qualified status for the purposes of the income inclusion rule and domestic minimum tax (including the QDMTT Safe Harbour).
On March 27, 2025, Law No. 22 of 2024 was published in Qatar’s Official Gazette. This implements the Pillar Two Income Inclusion Rule and a Domestic Minimum Top- Up Tax from January 1, 2025.
On March 27, 2025, Bulgaria’s 2025 State Budget Law (the ‘2025 Budget Law’) was published in the Official Gazette. This includes a number of changes to the Corporate Income Tax Law to amend the Global Minimum Tax provisions from January 1, 2024.
Insurance Investment Entities are subject to special treatment under the Pillar Two GloBE Rules. Read our analysis of the key provisions.
On March 20, 2025, the Swedish Ministry of Finance issued a draft law to amend the Global Minimum Tax Act. The draft law is open for consultation until May 26, 2025. The purpose of the draft law is to implement the provisions of the June 2024 OECD Administrative Guidance into domestic law.
On March 18, 2025, the government approved a draft bill on the amendment of Liechtenstein’s Global Minimum Tax Act (‘the bill’). The bill is intended to implement domestically the OECD provisions for the exchange of information in the GloBE Information Return (GIR) under the multilateral agreement between competent authorities on the exchange of GloBE information (GIR MCAA).
On March 6, 2025 a Decree of the Italian Ministry of Finance on Notification Requirements for Global Minimum Tax purposes was published in the Official Gazette. This provides more details on the double filing relief notification under Article 51(4) of Legislative Decree December 27, 2023, no. 209 (the Global Minimum Tax Law).
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