Tax Updates: January 21st 2025
Consistent with our commitment to provide updated information on current tax issues
Consistent with our commitment to provide updated information on current tax issues
Article Posted date
21 January 2025
1 min read
New Pillar II rules Administrative Guidance issued by OECD
On 15 January 2025, OECD released additional Administrative Guidance with regards to Pillar II rules. In this context, OECD published a transitional central record with jurisdictions having implemented a Qualified Income Inclusion Rule (QIIR), a Qualified Domestic Minimum Top-up Tax (QDMTT) and be eligible for QDMTT Safe Harbour.
Said record will be constantly updated with new jurisdictions on a regular basis. On the other hand, the absence of jurisdictions that have enacted such rules from the record does not imply their rules are not qualified; rather, it indicates that the review process is still ongoing.
Greece is included the transitional central record thereby entailing that where Greek DMTT is paid, then no additional top-up tax should in principle be collected for Greek CEs by jurisdictions of parent entities of an MNE Group through IIR mechanism. Conversely, no top-up tax should in principle be collected in Greece for Greek parent entities through IIR mechanism, in case foreign CEs are located in jurisdictions included in the transitional central record.
Moreover, OECD released a Multilateral Competent Authority Agreement for the exchange of Global Information Return (GIR). In this context, jurisdictions entering into said agreement will be exchanging GIRs, so that no separate fillings will in principle be required for CEs of the same MNE Group.
The new Administrative Guidance also contains further clarifications regarding Pillar II rules and an updated version of the GIR with relevant guidance regarding its completion.
