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Pillar Two (Pillar 2) - Global Minimum Tax

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Read moreExpertsNews & KnowledgeLatest NewsBrochuresNewslettersNews & Knowledge Welcome to WTS Global Insights. Here you will find news and updates from our worldwide network. Read moreHot TopicsPillar TwoPillar Two TeamPillar Two - Implementation Status WorldwideFIT for CBAMViDA - VAT in the Digital AgeEU WHT ReclaimsProSports Tax GroupplAIgroundHot Topics Overview of the current "Hot Topics" in the tax industry and how we can support with individual questions. Read moreCulture & CareerCulture and LeadershipDiversityWTS Global AcademyCareerCulture and Leadership WE PLAY DIFFERENT. Read moreCareer Join the game-changers. Read moreLocationsSearchHomeHot TopicsRead moreView ProfileViewViewRead moreBelgium has taken further steps in the implementation of the OECD/G20 Pillar 2 rules with the publication of the draft Income Inclusion Rule (IIR) return and accompanying draft instructions, and Circular 2026/C/41 (addendum), which provides clarification on the use of exchange rates where the presentation currency of the consolidated financial statements differs from the euro. Belgium: Updates on the Belgian Pillar 2 Implementation Read moreThe purpose of this note is to provide a didactic presentation of the reporting obligations, particularly aimed at the many "small groups" subject to Pillar Two regulations which are still at the beginning of their project and the French subsidiaries of foreign groups subject to this regulation. France: Pillar Two - Overview of the Reporting Obligations for Constituent Entities Established in France Read moreThis article summarizes the 2025 Finance bill, enhancing the global minimum tax regime with OECD instructions on deferred taxes and "transparent" entities, effective for financial years ending after Dec 31, 2024 France: Amendments made by the Finance bill for 2025 to the Pillar Two mechanism Read moreWe are thrilled to share with you a roundup of significant updates from December 2024 regarding Pillar Two, including insights into regulatory changes, compliance requirements, and implementation progress across various jurisdictions. Pillar Two: Updates December 2024 Read moreAustria’s Pillar Two rules allow the ultimate parent entity to designate a "single taxable CE" for top-up tax, with the declaration to be filed via FinanzOnline by 31 December 2024. Austria: Pillar Two - Selection of Taxable Constituent Entities Until 31 December 2024 Read moreThe Belgian tax authorities (FPS Finance) announced that from 2 September 2024 multinational enterprises (MNE) and large domestic groups subject to the minimum tax for MNE groups and large domestic groups (Pillar 2) can start their Pillar 2 related prepayments. Belgium: Pillar Two prepayment system Read moreThe EU's Pillar Two Directive complements CFC legislation from ATAD. Austria adopted it in 2023, after implementing a CFC regime in 2018. The OECD later identified conflicts between the CFC legislation and Pillar Two. Austria: Austria amends CFC rules to avoid double taxation due to Pillar Two Read moreWe are thrilled to share with you a roundup of significant updates from June 2024 regarding Pillar Two, including insights into regulatory changes, compliance requirements, and implementation progress across various jurisdictions. Pillar Two: Updates June 2024 Read moreWe are thrilled to share with you a roundup of significant updates from May 2024 regarding Pillar Two, including insights into regulatory changes, compliance requirements, and implementation progress across various jurisdictions. Pillar Two: Updates May 2024 Read moreWe are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide! Pillar Two: Updates April 2024 Read moreWe are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide! Pillar Two: Updates March 2024 Read moreWith Pillar Two enacted in over 25 jurisdictions, it's crucial for calendar-year companies to understand the forecasted impacts on their Q1 2024 income tax provisions. Discover the checklist of action items curated by GTM, our member firm in the US, to navigate the complexities of new tax regulations. Pillar Two: Q1 2024 Checklist for US MNEs Read moreWe are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide! Pillar Two: Updates February 2024 Read moreWe are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide! Pillar Two: Updates January 2024 Read moreWe are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide! Pillar Two: Updates November 2023 Read moreWe are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide! Pillar Two: Updates September 2023 Read moreWe are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide! Pillar Two: Updates July 2023 Read moreOn 17 July 2023, the OECD (i.e. the Inclusive Framework, “IF”) published various new documents relating to the introduction of Pillar Two. In this article, we present an initial overview of the key aspects covered in these documents. Pillar Two: Further OECD guidance Read moreFind out the latest on the implementation of public CbCR in the Netherlands and what it means for multinational enterprises. Discover key details and important next steps in this newsflash. Implementation public CbCR in the Netherlands Read moreDiscover the latest insights from Lee & Ko, our trusted tax experts in South Korea, in their article published in Bloomberg Tax. Uncover the groundbreaking developments of South Korea's Pillar Two rules and explore their implications for foreign multinational enterprises operating in the country. South Korea First to Enact Global Minimum Tax Rules Amid Concerns Read moreWe are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide! Pillar Two: Updates June 2023 Read moreWe are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide! Pillar Two: Updates May 2023 Read moreWe are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide! Pillar Two: Updates April 2023 Read moreWe are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide! Pillar Two: Updates March 2023 Read moreTemporary and permanent reliefs bring simplifications. OECD publishes Safe Harbours for Pillar Two Read moreOn 20 December 2022, the OECD/G20 GloBE Inclusive Framework released its Pillar Two Safe Harbour and Penalty Relief guidance document. Read an article about the key elements of the transitional and potential permanent safe harbours from our tax experts in Belgium. Belgium: OECD’s Recently Released Safe Harbours and Penalty Relief Guidance : Solving key issues that MNEs face, or just a drop in the ocean? Read moreThe Finance Ministry published an announcement dated 20 Dec 2022 on the base rate and margin notice for transfer pricing purposes in personal income tax (PIT) and corporate income tax (CIT). The announcement came into force on 1 January 2023. Poland: „Safe harbour” for loans in 2023 Read more15 December 2022 saw the Council of the European Union reach its unanimous agreement on the “Council Directive on ensuring a global minimum level of taxation for multinational and large-scale domestic groups” in a written procedure. Germany: Council of the EU reaches agreement on global minimum taxation (Pillar Two) Read moreAll EU member states to introduce global 15% minimum tax by the end of 2023! Pillar Two: Breaking News! EU Pillar Two Directive is coming Read moreSwitzerland will implement the BEPS 2.0 Pillar Two minimum taxation by introducing a new minimum tax at the federal level. Switzerland: Implementation of OECD minimum tax rate Read moreRecently the US corporate alternative minimum tax (AMT) was resurrected by the Inflation Reduction Act of 2022. It is structured in a significantly different way than the previous one and only applicable to select corporate taxpayer’s. Meanwhile it is still unclear how the US AMT will interact with the OECD Pillar Two rules. US: Corporate alternative minimum tax in light of the Pillar Two rules Read moreOn October 24, 2022, the Netherlands published the draft bill on Pillar Two called ‘Minimum Tax Rate Act 2024’ (news item). This draft bill is open for public consultation until December 5, 2022. The Netherlands: Draft bill to implement Pillar Two rules Read moreOverview of the procedural specifics and technical issues to consider in the five steps published by the OECD. Pillar Two - Top-Up Tax Calculation in Five Steps Read moreOn 20 July 2022, the UK government published draft legislation on the Pillar Two Income Inclusion Rule (IIR) and its response to the public consultation on the UK Implementation of Pillar Two with the governmental position in the key areas. UK: Draft legislation on the Pillar Two Income Inclusion Rule Read moreTo support companies in implementing and complying with these rules in the future, WTS relies on three different technical solutions for an integrated Tax Reporting and Pillar Two process. Pillar Two - Technical Implementation Options Read moreOur Global Services Learn more about our network partners and their services. 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