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Many countries still need to define the details of their QDMTTs
via bylaws or legislative amendments. However, for some
countries it is already clear that their minimum tax systems do
not qualify as QDMTTs. Such is the case with Cyprus, where
the minimum tax legislation prescribes ‘push-down’ of certain
taxes including CFC taxes (which is not provided for in the GloBE
Rules and their Commentary). Due to such deviations, other
jurisdictions may not view the Cyprus domestic top-up tax as
QDMTT but rather as a covered tax.

Last but not the least, countries implementing minimum tax
rules differ in regard to compliance requirements and deadlines.
In addition to Belgium, which, as explained above, has added
registration and additional compliance requirement, UK and
Ireland for example also oblige the MNE groups to register with
the tax authority within 6 and 12 months respectively, after the
end of the accounting period that makes them subject to the
rules. Also, in addition to Global Information Return (“GIR”),
introduced by the GloBE Rules, some countries require filing
of a tax return, where the deadlines are in some cases shorter
than for GIR. Taking into account that GloBE Rules rely on
financial statements and country-by-country reporting (“CbCR”)
for the purpose of safe harbours, the MNE groups will need to
carefully track their compliance calendars and align their Pillar
II-related procedures accordingly.

From the above overview it is clear that, while Pillar II
represents a step further in the harmonization of corporate
taxation across jurisdictions, disparities remain and should
be closely monitored. Global minimum tax has arrived
(even traditional tax havens such as Channel Islands have
implemented it) and taxpayer and tax consultants should
adapt their approach to understand and work with the general
rules and jurisdictional variations. The growth of multinational
companies will be dependent on their ability to navigate the
evolving global tax landscape. Tax consultants' expertise will be
essential in assisting them in this difficult transition.

Bu makalede yer alan açıklamalar, yazarının konu hakkındaki kişisel
görüşünü yansıtmaktadır. Makaledeki bilgi ve açıklamalardan dolayı
EY ve/veya Kuzey YMM ve Bağımsız Denetim A.Ş.’ye sorumluluk
iddiasında bulunulamaz. Mevzuatın sık değiştirilen ve farklı anlayışlarla
yorumlanabilen yapısı nedeniyle, herhangi bir konuda uygulama
yapılmadan önce konunun uzmanlarından profesyonel yardım alınmasını
tavsiye ederiz.
Eylül 2024 Eylül 2024 23