Highlights: A new global tax rule (UTPR) starts in 2025 to ensure large multinational enterprises pay at least a 15% effective tax rate worldwide, even if the main rule doesn’t apply. Compliance will become more complex, as each country may implement the rule differently, requiring companies to monitor and adjust for tax rules in […] … Read More
As we move through 2025, the Global Minimum Tax regime—also known as GloBE or OECD BEPS 2.0 Pillar 2—has become firmly established in the global tax landscape. What began with South Korea’s pioneering implementation has now expanded across the globe, with most of the 137 signatory countries having enacted domestic legislation to enforce the 15% […] … Read More
On June 15, 2017, U.K. HMRC issued updated guidance on the Worldwide Disclosure Facility (WDF). See BEPS Action 12. On December 31, 2015, all HMRC offshore facilities closed. The WDF is currently available to anyone who would like to disclose a U.K. tax liability that relates wholly or partly to an offshore issue, which includes […] … Read More
On August 24, 2017, Portugal published Law No. 98/2017 in the official gazette, which implements EU Directives 2015/2376 and 2016/881 on the automatic exchange of tax ruling and CbC reporting information among EU member states, respectively. The measures apply retroactively from January 1, 2017. Tax Rulings (BEPS Action 5) Building on the OECD work on […] … Read More
The OECD has released comments, dated as of August 11, 2017, to the July 11, 2017 public release of the draft contents of the 2017 update to the OECD Model Tax Convention (MTC). The OECD received comments from a variety of international associations and groups. Outlined below are some of the comments received by the […] … Read More
On August 1, 2017, Greece published Law No. 4484 (the “Law”) in the Government newspaper, The Hellenic Democracy. The Law implements EU Directive 2016/881 (amending Directive 2011/16, which was previously amended by Directives 2014/107 and 2015/2376) on the mandatory automatic exchange of tax information (e.g., country-by-country (CbC) reports) into domestic legislation. See BEPS Action 13. […] … Read More