Italy: CFC rules related to GloBE pillar 2 amended to include 15% tax rate option and substitute tax
On 19 December 2023, Italy's Council of Ministers passed a legislative decree to enforce the tax reforms related to international taxation. This includes implementing the Pillar 2 global minimum tax under Council Directive (EU) 2022/2523 of 14
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Netherlands: Parliament passes tax plan for 2024 and pillar 2 global minimum tax
On 19 December 2023, the Dutch Senate (upper house of parliament) passed the Tax Plan for 2024, which includes the Pillar 2 global minimum tax and other tax measures. On 27 October 2023, the House of Representatives (lower house) approved the Tax
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Hungary offers tax amnesty for previously ineligible shares
Recently, Hungary implemented a tax legislation that grants one-time amnesty for any capital gains on the disposal of shares in subsidiaries that had not previously chosen to participate in Hungary's capital gains exemption regime. Hungary’s
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Austria: Nationalrat approves bill to implement Pillar 2 global minimum tax
On 14 December 2023, the Austrian lower house of parliament (Nationalrat) approved Bill No. 2322 dB on the execution of the Minimum Taxation Directive (2022/2523) to ensuring a global minimum level of taxation for multinational enterprise groups and
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Belgium passes draft bill on GloBE rule
On 14 December 2023, the Belgian parliament approved the draft bill to implement the global minimum tax, Pillar 2, into Belgian law. On 30 November 2023, the draft law for implementing the global minimum tax Pillar Two was accepted by the Belgian
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Bulgaria: National Assembly approves Pillar 2 global minimum tax rules
On 12 December 2023, Bulgaria's National Assembly declared the approval of amendments to key tax laws, namely the Local Taxes and Fees Act, the Value Added Tax Act and the Corporate Income Tax Act. Notably, significant changes were made to the
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Hungary publishes GloBE laws in the official gazette
On 30 November 2023, Hungary published Law LXXXIII of 2023 on the amendment of individual tax laws and Law LXXXIV of 2023 on additional taxes in Gazette No. 171 of 30 November 2023. The recently enacted laws ensure a global minimum tax level and
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Latvia announces to implement pillar two minimum tax rules partially
Latvia's Ministry of Finance announced it had finalized a draft legislation for partially implementing the Pillar 2 global minimum tax (GloBE) rules as per Council Directive (EU) 2022/2523 of 14 December 2022. The partial implementation
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Netherlands: Senate passes public CbC reporting bill
The Dutch Senate (upper house of parliament) has passed the bill for implementing public Country-by-Country (CbC) reporting as required by Directive (EU) 2021/2101. The bill facilitates the partial implementation of Council Directive (EU) 2021/2101,
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Belgium proposes new draft law for CFC rules
The Belgian government has submitted a new draft bill to parliament for implementing stricter rules concerning the taxation of the undistributed income of a controlled foreign company (CFC), shifting from model B (targeting tax avoidance
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Spain releases 2024 FTT list for companies
On 13 December 2023, the Spanish Tax Agency released the list of companies whose market capitalization value surpassed EUR 1 billion as of 1 December 2023. The list pertains to financial transaction tax (FTT). The financial transactions tax (FTT)
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Spain: Valencia & Catalonia propose retroactive personal income tax reductions (IRPF) for FY 2023
The Generalitat of Catalonia is working on reducing the regional section of the Personal Income Tax (IRPF). The “Govern” proposes in the budget accompanying law, cutting one percentage point – from 10.5% to 9.5% – the first tranche of the
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Poland: Draft bill raises limits for tax-deductible costs
On 11 December 2023, Poland’s Lower House of Parliament received a draft law from the government in which it amended the Act on Personal Income Tax and the Act on Corporate Income Tax. The draft law increases the applicable limits to 100% for the
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Portugal approves State Budget for 2024
On 29 November 2023, the Portuguese parliament approved the State Budget for 2024 (Draft Law 109/XV/2), including some modifications proposed after the primary proposal on 10 October 2023. This budget includes the following tax measures:
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Cyprus and France sign the DTA to strengthen economic ties
On 11 December 2023, the Convention for the Elimination of Double Taxation with Respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance, and its Protocol between the Republic of Cyprus and the French Republic, was signed in
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Denmark: Parliament passes pillar two global minimum tax law
On 7 December 2023, the Danish Parliament passed legislation to implement the Pillar 2 global minimum tax (GloBE) rules. This legislation closely adheres to the framework established by the Council Directive (EU) 2022/2523 of 14 December 2022. On 23
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Germany: MOF issues draft guidance on anti-tax avoidance measures
On 30 November 2023, the German Ministry of Finance (MoF) issued draft guidance on anti-tax avoidance measures targeting non-cooperative jurisdictions. This follows the 2021 Tax Haven Defense Act, responding to EU guidelines against harmful tax
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Czech Senate passes global minimum tax rule
On 1 December 2023, the Czech Senate passed a law to enforce the Pillar 2 global minimum tax under Council Directive (EU) 2022/2523 of 14 December 2022. On 27 October 2023, the law was approved by the Chamber of Deputies. On 30 August 2023, the
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