Book6 |
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| A | B | C | D | E | F | G | H | I |
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2 | Country or region | Status of enactment | Income Inclusion Rule (IIR) | Undertaxed Payments Rule (UTPR) | Qualified Domestic Minimum Top-up Tax (QDMTT) | Covered Taxes | Qualifying Refundable Tax Credits | Transitional Safe Harbour | Compliance / Filing Requirements |
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3 | Albania | No announcement yet | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | No information available. | No information available. | No information available. | No information available. |
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4 | Angola | No announcement yet | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | No information available. | No information available. | No information available. | No information available. |
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5 | Argentina | No announcement yet | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | No information available. | No information available. | No information available | No information available. |
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6 | Armenia | No announcement yet | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | No information available. | No information available. | No information available | No information available |
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7 | Australia | In the 2023-24 Budget, the Government announced the implementation of a 15% global minimum tax and domestic minimum tax, key aspects of Pillar Two of the OECD/G20 Two-Pillar Solution to address the tax challenges arising from the digitalisation of the economy. The IIR will apply for fiscal years starting on or after 1 January 2024. The UTPR will apply for fiscal years starting on or after 1 January 2025. The domestic minimum tax will apply for income years starting on or after 1 January 2024. The draft legislation has not been released yet. | Entry into force: 1 January 2024 The IIR will apply to fiscal years that begin on or after 1 January 2024 to: Multinational groups with annual global revenue of EUR750 million or more. In-scope multinationals across all sectors subject to certain exclusions for investment funds, pension funds, government entities, international organisations, not-for-profit organisations, as defined in the OECD Global anti- Base Erosion (GloBE) Rules, and income associated with international shipping | Entry into force: 1 January 2025 The UTPR will apply to fiscal years that begin on or after 1 January 2025 to: Multinational groups with annual global revenue of EUR750 million or more. In-scope multinationals across all sectors subject to certain exclusions for investment funds, pension funds, government entities, international organisations, not-for-profit organisations, as defined in the OECD Global anti- Base Erosion (GloBE) Rules, and income associated with international shipping | Entry into force: 1 January 2024 The domestic minimum tax will apply to fiscal years that begin on or after 1 January 2024 to: Australian operations of multinational groups with annual global revenue of EUR750 million or more. In-scope multinationals across all sectors subject to certain exclusions for investment funds, pension funds, government entities, international organisations, not-for-profit organisations, as defined in the OECD Global anti- Base Erosion (GloBE) Rules, and income associated with international shipping | No information available. | No information available. | No information available | No information available. Federal Budget 2023-24 - Australia will implement key aspects of the OECD's 'Pillar Two' framework, including a domestic minimum tax, with an effective date for some measures from 1 January 2024. Read more |
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8 | Austria | No announcement yet. Austria has to implement the Pillar Two rules in line with the Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union. | Entry into force: To be confirmed No announcement yet. It is expected that Austria will follow the overall implementation timeline proposed by the Directive (EU) 2022/2523 of 14 December 2022, i.e., 2024 for the IIR and 2025 for the UTPR. | Entry into force: To be confirmed No announcement yet. It is expected that Austria will follow the overall implementation timeline proposed by the Directive (EU) 2022/2523 of 14 December 2022, i.e., 2024 for the IIR and 2025 for the UTPR. | Entry into force: To be confirmed No announcement yet. Austria can adopt a QDMTT as part of its overall implementation of Pillar Two under Art. 11 of the Directive (EU) 2022/2523 of 14 December 2022 | No information available. | No information available. | No information available | No information available. |
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9 | Azerbaijan | No announcement yet | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | No information available. | No information available. | No information available | No information available |
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10 | Bahamas | On May 17 the Bahamas government published a public consultation gthe Green Paper on Corporate Income Tax Strategies for the Bahamash, which sets out the options under consideration for transitioning away from the existing business licence tax (BTL) regime, as well as implementing changes to address Pillar Two | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | No information available. | No information available. | No information available | No information available |
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11 | Bahrain | No announcement yet | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | No information available | No information available. | No information available | No information available |
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12 | Barbados | The Prime Minister announced In the Budgetary Proposals and Financial Statement 2023 on 14 March 2023 that the Government was deep in consultations with the Barbados Revenue Authority. The Prime Minister indicated that she would likely come back to the country within six months on this issue. | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | No information available | No information available | No information available. | No information available. |
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13 | Belgium | The Belgian Minister of Finance has announced a phased tax reform, with one phase dedicated to Pillar Two enactment in Belgium. Currently, stakeholder consultations are taking place with advisors and businesses. Draft legislation is expected to be published in the summer 2023, with a vote shortly after that. In general, the Pillar Two implementation will be in line with the OECD model rules and the Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union. The government already agreed on some core principles of the Pillar Two implementation in Belgium including a decision that a QDMTT will be introduced, that the Pillar Two QDMTT will be payable in the course of the year (via the Belgian tax prepayment system) and that the R&D tax credit will be modified to qualify as a qualifying tax credit. | Entry into force: 1 January 2024 It is expected that Belgium will follow the overall implementation timeline proposed by the Directive (EU) 2022/2523 of 14 December 2022, i.e., 2024 for the IIR and 2025 for the UTPR. | Entry into force: 1 January 2025 It is expected that Belgium will follow the overall implementation timeline proposed by the Directive (EU) 2022/2523 of 14 December 2022, i.e., 2024 for the IIR and 2025 for the UTPR. | Entry into force: To be confirmed Most likely Belgium will include a QDMTT in the draft legislation. | No information available. | The Government has expressed that the R&D tax credit will be modified to qualify as a qualifying tax credit. | It is expected that Belgium will follow the Transitional Safe Harbour guidance included in the Implementation Framework issued by the OECD in December 2022. | No information available. Belgium agrees on core principles for implementation of the Global Minimum Tax (GloBE/Pillar 2) for MNEfs and some additional tax measures The Belgian government reached an agreement on the Federal budget. After long discussions within the government, a number of measures have been decided that will reduce expenditures and measures that will increase revenue. Read more |
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14 | Bermuda | In the 2023 Budget, the Bermuda Premier announced plans for the second half of 2023 on a decision in relation to Pillar Two (and potentially a QDMTT) and the 8,000 exempted companies in Bermuda which are in possession of a certificate from the Bermuda Government that states that they will not be charged taxes on their income until 2035 (should an income tax be enacted). There is a committee of industry representatives formed with a report to the Government for consideration due this Summer 2023 (June / July). | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | Entry into force: To be confirmed No announcement yet | No information available | No information available | No information available | No information available. |
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