Description

Introduced Multinational Enterprise (Minimum Tax) Bill (No. 33/2024)

On 9 September 2024, the Multinational Enterprise (Minimum Tax) Bill (No. 33/2024) was introduced. The Bill seeks to implement the OECD's Global Anti-Base Erosion Model Rules (Pillar 2) by introducing a minimum tax rate of 15% for multinational enterprise (MNE) groups with consolidated revenues of EUR 750 million or more. Furthermore, the Bill aims to implement top-up taxes on under-taxed income to ensure MNEs pay a minimum level of tax on profits. In addition, the Bill introduces measures for MNE groups to register and designate local filing entities and outlines powers for the Comptroller of Income Tax in obtaining information, enforcing penalties, and managing appeals. Furthermore, it details specific exclusions such as substance-based income exclusion and de minimis rules, and provides regulations for handling joint ventures and multi-parent groups.

Original source

Scope

Policy Area
Taxation
Policy Instrument
Direct taxes including Digital Service Taxes
Regulated Economic Activity
cross-cutting
Implementation Level
national
Government Branch
legislature
Government Body
parliament

Complete timeline of this policy change

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2024-09-09
under deliberation

On 9 September 2024, the Multinational Enterprise (Minimum Tax) Bill (No. 33/2024) was introduced. …

2024-10-15
adopted

On 15 October 2024, the Multinational Enterprise (Minimum Tax) Act (No. 33/2024) was adopted. The A…