Singapore consults on Pillar Two Minimum Tax regulations
Singapore aims to introduce streamlined methods for companies to calculate their top-up taxes in line with the proposed global minimum tax. The global minimum tax, or Pillar Two, aims to establish a 15% effective tax rate for multinational
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Brazil implements Additional Social Contribution to Net Profit as Pillar 2 top-up tax
Brazil has enacted Provisional Measure No. 1.262 of October 3, 2024, and Normative Instruction No. 2.228 of October 3, 2024, to introduce an Additional Social Contribution to Net Profit (CSLL). This initiative aims to comply with the requirements of
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European Commission refers Spain, Cyprus, Poland, Portugal to court for failing to transpose Pillar Two Minimum Taxation Directive
The European Commission (EC) decided to refer Spain, Cyprus, Poland, and Portugal to the Court of Justice of the European Union for failing to notify measures for the transposition into national law of Council Directive (EU) 2022/2523 of
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Denmark: 2024-25 legislative plan proposes updates to minimum tax, transfer pricing to match OECD rules
Denmark's government announced the legislative programme for the parliamentary year 2024-25 on 1 October 2024. The bill follows up on the government platform "Responsibility for Denmark" from December 2022 and the agreement on "A Stronger Business
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Poland: Lower parliament evaluates draft law to enact Pillar Two global minimum tax
Poland's Sejm (lower house of parliament) is currently reviewing a draft law, submitted on 25 September 2024, to implement the Pillar Two global minimum tax in accordance with Council Directive (EU) 2022/2523 from 14 December 2022. The draft law
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Puerto Rico consults implementation of Pillar Two GloBE rules
Puerto Rico's Department of the Treasury has initiated a Public Consultation on the Implementation of the Pillar Two GloBE Rules in Puerto Rico, set to conclude on 10 October 2024. Pillar Two ensures that particular taxpayers are subject to a
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UK to consult Multinational Top-up Tax and Domestic Top-up Tax – further draft guidance
HM Revenue & Customs (HMRC) has initiated a public consultation on the third version of UK's Pillar Two global minimum tax rules. Comments must be submitted by 23 October 2024. HMRC released additional draft guidance for consultation
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Finland proposes amendments to minimum tax act
Finland's government presented the draft legislation HE 98/2024 vp to the parliament to amend the Minimum Tax Act on 20 September 2024. The Minimum Tax Act was enacted at the end of 2023 to facilitate the implementation of the Pillar Two global
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OECD: Nine jurisdictions sign pact to implement Pillar Two STTR, ten more to join
The Organisation for Economic Cooperation and Development (OECD) released a statement yesterday, 19 September 2024, following the signing ceremony of the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule
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US: House Republican leaders, Ways and Means members oppose Pillar Two deal in letter to OECD
Key Republican leaders in the US House of Representatives, including Speaker Mike Johnson and House Majority Leader Steve Scalise, House Majority Whip Tom Emmer, House Ways and Means Committee Chairman Jason Smith, and and all other Republican
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US: IRS grants limited relief for underpayment of CAMT-related estimated tax
The US IRS released Notice 2024-66, on 12 September 2024, which provides relief from the addition to tax under section 6655 of the Internal Revenue Code (Code) for underpayment of estimated income tax by a corporation to the extent the amount of any
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Philippines sets 20% corporate tax for companies under enhanced deduction
The Philippine Senate passed the Corporate Recovery and Tax Incentives for Enterprises to Maximize Opportunities for Reinvigorating the Economy (Create More) Act on 9 September 2024. The Create More Act modifies the Create Act, which was enacted
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US: IRS proposes new corporate alternative minimum tax (CAMT) rules
The US Internal Revenue Service (IRS) issued IR-2024-235 on 12 September 2024, proposing regulations to provide guidance on the Corporate Alternative Minimum Tax (CAMT). The Inflation Reduction Act created the CAMT, which imposes a 15% minimum
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Belgium launches prepayment system for pillar two taxes
The Belgian tax authorities Federal Public Service (SPF) announced that the prepayment system for the Domestic Minimum Top-Up Tax (DMTT) and Income Inclusion Rule (IIR) top-up tax was activated on 2 September 2024. Taxpayers who prepay these
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Brazil to tax big tech firms if revenue declines
Brazil's Ministry of Finance announced that it plans to present proposals to Congress to tax big tech companies and implement a global minimum tax of 15% for multinational corporations on 2 September 2024. These new tax measures will be enforced
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Iceland consults Pillar Two global minimum tax
Iceland’s Ministry of Finance and Economic Affairs has announced plans to introduce an amendment during the autumn parliamentary session on 28 August 2024 proposing a minimum tax rate of 15% for multinational enterprises (MNEs) with annual
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Canada consults global minimum tax, capital gain inclusion rate draft legislation
Canada’s Department of Finance invites public feedback on draft legislative proposals to implement the 2024 Budget and other previously announced tax measures. These proposals include changes such as introducing a global minimum tax and increasing
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Israel to implement Pillar Two QDMTT in 2026
Israel's Ministry of Finance announced its initial plan to implement the qualified domestic minimum top-up tax (QDMTT) in 2026, as part of the OECD Pillar Two international tax reform. The enforcement of QDMTT will eliminate the need for Israeli
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