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Five EU Member States Intend to Defer Pillar 2 Global Minimum Tax Rules

01 November 2023

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Proposed Changes

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European Union-Estonia-Latvia-Lithuania-Malta-Slovak Republic

Five EU Member States have reportedly informed the European Commission that they intend to defer the application of the Pillar 2 global minimum tax (GloBE) rules as provided by Council Directive (EU) 2022/2523 of 14 December 2022, including Estonia, Latvia, Lithuania, Malta, and the Slovak Republic. As allowed by the Directive, Member States in which no more than 12 ultimate parent entities of groups within the scope of the Directive are located may elect not to apply the income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR) for six consecutive fiscal years beginning from 31 December 2023 (i.e., the...