Pillar Two: Updates September 2023

The EU's commitment to implementing global minimum tax rules (Pillar Two) by the end of 2023 has triggered increased legislative activity across EU countries. In September, several nations took significant steps, including:

• Bulgaria: On September 26, 2023, the Bulgarian Ministry of Finance introduced a draft law to implement the EU Global Minimum Tax Directive, including IIR, UTPR, and a domestic QDMTT, which could significantly impact the country's existing low corporate income tax rate of 10%.
• Finland: On September 1, 2023, Finland updated its draft legislation, introducing a Finnish DMTT for specific financial years.
• France: On 27 September 2023, the French Government released the draft Finance Bill for 2024 outlining the transposition of the EU Minimum Taxation Directive into French domestic law.
• Hungary: Minister of Finance announced a consultation on the transposition of the EU Minimum Tax Directive into domestic law. The government is dedicated to retaining Hungary's competitive tax environment.
• Italy: The Ministry of Economy and Finance has published for consultation the draft legislative decree implementing EU Minumum Tax Directive.
• Lithuania: Lithuania discussed the potential transposition of the EU Minimum Tax Directive into its tax system, with consideration for deferring the implementation of certain rules until 2029 and introducing a Domestic Minimum Top-up Tax in 2025. However, no final decision was made during the discussions, and a public consultation on the draft legislation is expected in the future.
• Netherlands: The Dutch Ministry of Finance issues a memorandum addressing the parliamentary questions regarding bill on the Minimum Profit Tax Act 2024 (Pillar Two).
• Sweden: Sweden's Ministry of Finance released a draft bill aligning with the EU Minimum Tax Directive, including DMTT, IIR, and UTPR application timelines.
• Switzerland: ›Switzerland enacted a constitutional amendment empowering the government to issue temporary ordinances for the execution of the OECD’s Pillar Two Model Rule.
• Turkey: The Turkish Public Oversight, Accounting, and Auditing Standards Authority made amendments to Turkish Accounting Standard (TAS) 12, aligning with Pillar Two Model Rules.

These developments underline the evolving landscape of Pillar Two implementation across the globe, stressing the need to stay informed and adapt to changing tax regulations.

WTS Global, with its expansive network spanning over 100 countries, remains committed to providing a comprehensive overview of the Pillar Two implementation status in 72 countries.

Our tax experts diligently update this information on a monthly basis to offer the most current insights.

If you have specific inquiries regarding the Pillar Two rules and their implications for your business, we encourage you to reach out to our tax experts. We stand ready to assist you in navigating this intricate landscape.

Yours sincerely,

WTS Global