Pillar Two: Updates March 2023

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

With representation in over 100 countries, WTS Global provides you with the regular updates on the implementation status of the Pillar Two rules in various jurisdictions.

Over the past month, a growing number of states have initiated the process of introducing a global minimum tax into their domestic legislation, including:

Belgium: Belgian Finance Minister introduced a “broad tax reform” package that includes a proposal to implement a global minimum tax.

Germany: The draft bill for implementing Pillar Two was published. 

Japan: Japan enacted a Pillar Two Income Inclusion Rule from April 1, 2024. 

Malaysia: Malaysian government will conduct a detailed study, following which the government plans to implement the Qualified Domestic Minimum Top-up Tax, effective for the year 2024 tax year.

South Africa: The government will publish a draft position on the implementation of Pillar Two for public comment and draft legislation will be prepared for inclusion in the 2024 Taxation Laws Amendment Bill.

South Korea: Korea has enacted the first domestic law to give effect to the Pillar Two GloBE rules from January 1, 2024. 

Spain: A public consultation has been posted prior to the preparation of the draft law that will transpose the directive, with a deadline to send comments till March 24.

Thailand: The Thai government has assigned relevant agencies to commence action on proposals to implement the global minimum tax.

United States: The Green Book for the 2024 fiscal year released by the Biden Administration includes a proposal to align the US GILTI rules with the Pillar Two rules.

Vietnam: The Ministry of Finance issued a proposal for public consultation on revising the corporate tax regime, which includes a provision to reform corporate tax incentives to align with Pillar Two.

At the same time many countries have not yet made any public statements regarding the Pillar Two implementation in the near future. However, given that more and more countries have already initiated the implementation process, the situation could change abruptly. 

If you would like to know the current information for your country, just click on it on our interactive map and find the relevant page in the overview.

Feel free to contact our tax experts in your jurisdiction if you have any questions on Pillar Two rules and their impact on your business.

We hope you find this overview useful and welcome your feedback and suggestions. 

Please find the Pillar Two - Country–by–Country Implementation Status here.

Yours sincerely,

WTS Global