Are you Pillar Two ready?

TP News brings to you a detailed country-by-country implementation report on Pillar Two rules covering 80+ tax jurisdictions, consisting of information on each and every aspect of Pillar Two rules that a given covered jurisdiction has either proposed or adopted.

The OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting has agreed a two-pillar solution to regulate digital economy taxation. Pillar Two introduces a global minimum effective tax rate (ETR) where MNEs with consolidated revenue over EUR 750m are subject to a minimum ETR of 15 percent on income arising in low-tax jurisdictions.

Pillar Two Model Rules agreed by the Inclusive Framework were published in December 2021, and a commentary to the GloBE rules was published in March 2022.

In December 2022, the OECD published the first three guidance papers relating to the implementation framework. In February 2023, the OECD published Administrative Guidance for Implementation of the Global Minimum Tax​​​.

In June 2023, the OECD’s Forum on Tax Administration Pillar Knowledge Sharing Network held its first virtual meeting of what will be a series of peer-to-peer knowledge-sharing events where experts from tax administrations in ‘early implementer’ jurisdictions will offer high-level practical advice and share lessons learned on administrative and implementation aspects of Pillar Two.

The following countries are included in the Report: Albania, Argentina, Australia, Austria, Azerbaijan, Bahamas, Bahrain, Barbados, Belgium, Bermuda, Brazil, Bulgaria, Canada, Cayman Islands, Chile, China, Colombia, Costa Rica, Croatia, Cyprus, Czech Republic, Denmark, Egypt, Estonia, Finland, France, Georgia, Germany, Gibraltar, Greece, Guernsey, Hong Kong, Hungary, Iceland, India, Indonesia, Ireland, Isle of Man, Israel, Italy, Jamaica, Japan, Jersey, Jordan, Kenya, Kosovo, Latvia, Liechtenstein, Lithuania, Luxembourg, Malaysia, Malta, Mauritius, Mexico, Netherlands, New Zealand, Nigeria, Norway, Oman, Pakistan, Panama, Poland, Portugal, Qatar, Romania, Saudi Arabia, Singapore, Slovakia, Slovenia, South Africa, South Korea, Spain, Sweden, Switzerland, Taiwan, Thailand, Turkey, Ukraine, United Arab Emirates (UAE), United Kingdom (UK), United States (USA), Uruguay, and Vietnam.

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