Minimum tax rate for large-scale groups (OECD Pillar Two)

CURRENT INFORMATION

• OECD has published new administrative guidance that includes a central record of legislation with transitional qualified status for purposes of the Global Minimum Tax. The record also includes information on whether the domestic top-up tax of a jurisdiction meets the conditions of the safe harbour rule on the dometic top-up tax. The Finnish income inclusion rule and domestic top-up tax have been considered to meet the criteria, also as regards the safe harbour rule on dometic top-up tax.

  • Global Anti-Base Erosion Model Rules (Pillar Two) | OECD

• OECD has released a new version of the international standard regarding the content of the information return on top-up tax, GloBE Information Return (January 2025), and an XML schema that will be used in the reporting of information and in the exchange of information between authorities.

  • Tax Challenges Arising from the Digitalisation of the Economy – GloBE Information Return (January 2025) | OECD

  • GloBE Information Return (Pillar Two) XML Schema | OECD

• The OECD has released a new commentary to the Model Rules: International tax reform: OECD/G20 Inclusive Framework on BEPS taking further steps on the implementation of the Two-Pillar Solution - OECD
• The newly published Consolidated Commentary to the Global Anti-Base Erosion Model Rules incorporates all guidance released up until December 2023.
• The act on the minimum tax rate for large-scale corporate groups (Laki suurten konsernien vähimmäisverosta 1308/2023) entered into force on 1 January 2024, and it is applied to accounting periods beginning on or after 31 December 2023.
• If you have any questions, please send email to: Minimivero(a)vero.fi