Pillar Two: Updates May 2023

We are witnessing significant legislative activity worldwide as jurisdictions move to implement the global minimum taxation rules. Several countries have already taken steps towards implementing these rules, with varying approaches and timelines. Notably, Korea and Japan have passed Pillar Two legislation, while draft legislation has been released in Germany, Ireland, Liechtenstein, the Netherlands, Sweden, Switzerland, and the UK.

In May, New Zealand has also published a draft law to implement the Pillar Two Global Minimum Tax and the Australian Government has announced the implementation of key aspects of the OECD Pillar Two rules as part of its 2023–24 Budget, effective from 1 January 2024.

Switzerland has issued an updated Draft Decree for the Pillar Two Global Minimum Tax, with a consultation period until September 14, 2023.  The Czech Republic has launched a public consultation on a draft bill to implement the Pillar Two Model Rules as outlined in the EU Minimum Tax Directive.

In Finland, the Ministry of Finance has begun preparations to implement the EU Minimum Tax Directive, with further information expected to be published during the legislative process.

In Norway, discussions regarding the two-pillar solution were included in the Revised National Budget 2022. Due to the complexities and uncertainties surrounding Pillar Two regulations, the consultation process and draft rules are planned to be presented in the spring of 2023. The goal is to introduce the rules from 2024 instead of 2023, given the demanding nature of their implementation.

Furthermore, the governments of Guernsey, Jersey, and the Isle of Man have jointly declared their approach to implementing the Pillar Two global minimum tax framework, intending to apply it to large multinational enterprises from 2025.

At WTS Global, we understand the importance of staying up-to-date with these developments. With our representation in over 100 countries, we provide a comprehensive overview of the implementation status of the Pillar Two rules in 72 countries.

Our tax experts continually update this information on a monthly basis, ensuring the most up-to-date insights.

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

Yours sincerely,

WTS Global