the Hong Kong Financial Services and Treasury Bureau (FSTB) and Inland Revenue Department (IRD) jointly released a consultation paper (Consultation Paper) on the implementation of the Global Anti-base Erosion Model Rules (Pillar Two) (GloBE Rules) and the Hong Kong ...
The federal government has also announced that it will implement a new global minimum tax and domestic minimum tax based on the OECD Global Anti-Base Erosion Model Rules. This proposal is part of a global initiative to limit tax competition by introducing a globally uniform floor. ...
During the Budget 2023 tabling session on 7 October 2022, the Malaysian Minister of Finance announced that the government will introduce global minimum effective tax rate as recommended under Pillar Two and plans to implement qualified domestic minimum top up tax (QDMTT) in 2024. We expect that ...
The new guidance is 111 pages long and covers questions of scope, income and taxes, insurance-specific points, transition, and qualified domestic minimum top-up taxes (QDMTTs). The guidance will be incorporated into the Pillar Two commentary (and a revised synthesized version of the ...
Income Inclusion Rule (IIR) and Qualified Domestic Minimum Top-Up Tax (QDMTT) Central to Vietnam’s GMT framework are the Income Inclusion Rule (IIR) and the Qualified Domestic Minimum Top-Up Tax (QDMTT). The IIR is a mechanism that requiresultimate parent entity, partially...
Indonesia will extend the current tax breaks for certain investments and introduce new incentives to ease the impact of the global minimum corporate tax rate, which will start next year. The Ministry of Finance said on 4 October 2024 that the tax holiday
Symposium: the global minimum tax – introductionxxxdoi:10.1111/1475Michael P. DevereuxFiscal Studies
2.0 Pillar Two. The Korean GloBE Rules are included in the Law for the Coordination of International Tax Affairs, effective on or after Jan. 1, 2024. South Korea is the first country to have codified the Organization for Economic Cooperation and Development Pillar Two into its...
The introduction of BEPS 2.0's GloBE rules marks a significant shift in global taxation, affecting MNEs with revenues of at least EUR 750 million. The rules set a 15% Global Minimum Tax and contain nuanced rules and intricate calculations that could lead to unexpected “top-up tax” liabi...
minimum tax). These regulations have put a spotlight on multinationals to refine global processes and increase granularity, transparency, and efficiency. This “call for clarity” has led to changes in policies and processes, such as transfer pricing, where audit defense is top of mind and ...