Italy gazettes decree on Pillar Two substance-based income exclusion
Italy published the Decree of 11 October 2024 in the Official Gazette on 23 October 2024, which addresses reducing the taxable base relevant to the global minimum tax. Earlier, Italy’s Ministry of Economy and Finance announced the Decree of 11
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US: Treasury, IRS relieves tax-exempt organisations from CAMT form filing for 2023 tax year
The US Department of Treasury and the Internal Revenue Service (IRS), in a release – IR-2024-277, granted a filing exception for tax-exempt organisations on 23 October 2024; they do not have to file Form 4626, Alternative Minimum Tax –
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Belgium consults Pillar Two supplementary tax form
Belgium's Federal Public Service (SPF) Finance has launched a consultation on the proposed annual supplementary national tax return form. The supplementary national tax applies to in-scope groups starting their tax years on or after 31 December
See MoreItaly implements decree on Pillar Two substance-based income exclusion
Italy's Ministry of Economy and Finance announced that the Decree of 11 October 2024, which provides implementation rules on the substance-based income exclusion (SBIE) to be applied when calculating the due amount of top-up tax and is being
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Poland to introduce cash grants amid potential impact of Pillar Two on investment zone incentives
Poland's Ministry of Development and Technology (MRiT) announced plans to reform the country's incentives system by introducing cash grants linked to investment profitability. The cash grant incentive regime aims to maintain Poland's
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Slovak Republic presents draft bill to amend Pillar Two rules
The Slovak Republic’s government presented a draft bill to the Parliament, on 11 September 2024, to amend the Pillar Two global minimum tax rules enacted on 8 December 2023. The proposed amendments cover financial accounting standards for
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Brazil consults Qualified Domestic Minimum Top-Up Tax
Brazil’s Federal Revenue Service has initiated a public consultation regarding the additional social contribution to net profits (Contribuição Social Para o Lucro LÃquido, CSLL). The consultation will be open from 4 October to 10 November,
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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
See MorePoland: 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
See MoreUS: 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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