Pillar Two: Updates November 2023

November 2023 has been a significant month for the advancement of Pillar Two, a core aspect of the global tax reform under the BEPS 2.0 initiative. Countries around the world continue to make strides in aligning their tax systems with these new international standards.

Here’s a brief overview of the progress made across various countries in November:

• Belgium has moved forward by sending its draft Pillar Two legislation to Parliament, aligning it with the EU Directive.
• Cyprus has confirmed its adoption of QDMTT and Undertaxed Profits Rule (UTPR) Safe Harbours, and released its draft Pillar Two legislation.
• Croatia opened its draft Pillar Two legislation for public consultation, in accordance with the EU Directive.
• Estonia has released draft legislation, deferring the implementation of Pillar Two until 2029.
• Finland is engaging in public consultation for Pillar One, alongside submitting its Pillar Two legislation to Parliament.
• Germany's Lower House has approved its Pillar Two legislation, marking a significant step forward.
• Hungary has submitted its draft Pillar Two legislation to Parliament.
• Ireland released its draft legislation for Pillar Two, encompassing IIR, QDMTT, and UTPR.
• Lithuania is focusing on the filing obligations in its draft Pillar Two legislation.
• Luxembourg has submitted amendments for its Pillar Two legislation to Parliament.
• Malaysia presented its draft legislation, including IIR and DMTT for 2025, notably excluding UTPR.
• Malta has chosen to delay the implementation of Pillar Two and will not introduce it in 2024.
• Netherlands’ Lower House has approved the Pillar Two bill, which is now moving to the Upper House for further discussion.
• South Korea released a Decree for public consultation, detailing the Pillar Two rules.
• United Arab Emirates may delay the implementation of QDMTT until 2025.

As these changes continue to evolve, it is imperative for businesses and stakeholders to stay informed and adapt to the new tax landscape. WTS Global, with its expansive network spanning over 100 countries, remains committed to providing a comprehensive overview of the Pillar Two implementation status in 72 countries. If you have specific inquiries regarding the Pillar Two rules and their implications for your business, we encourage you to reach out to our tax experts.

Read the Pillar Two - Implementation Status overview here.