On 15 October 2024, the Multinational Enterprise (Minimum Tax) Act (No. 33/2024) was adopted. The Act implements the OECD's Global Anti-Base Erosion (GloBE) Model Rules (Pillar 2). The Act introduces a 15% minimum tax rate for multinational enterprise (MNE) groups with consolidated revenues of EUR 750 million or more. It also enforces top-up taxes on under-taxed income to ensure MNEs meet the minimum tax requirement on their profits. Additionally, the Act mandates MNE groups to register and designate local filing entities, grants powers to the Comptroller of Income Tax to obtain information, enforce penalties, and manage appeals and outlines exclusions such as substance-based income exclusions and de minimis rules. It also provides regulations for handling joint ventures and multi-parent groups.
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