Description

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

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.

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…