The Ministry of Finance on September 18, 2024, launched a public consultation on draft legislation amending the Pillar Two rules that were enacted in December 2023.
The proposed amendments relate to:
- Transitional country-by-country (CbC) reporting safe harbor to reflect the OECD December 2023 administrative guidance, including anti-hybrid arbitrage rules that would apply to transactions entered into after December 18, 2023, and the transitional undertaxed profits rule (UTPR) safe harbor
- Removal of reference to IFRS as the relevant financial reporting framework for the purposes of the domestic minimum top-up tax (DMTT)
- Incorporation of several elements of the OECD administrative guidance (e.g., treatment of marketable transferable tax credits, changes for blended controlled foreign company (CFC) regimes, and equity investment inclusion election)
The consultation runs until October 18, 2024.
Read an October 2024 report prepared by KPMG’s EU Tax Centre