Between March 20, 2023 and March 31, 2023 the following four European jurisdictions published draft legislation to implement the minimum tax for large multinationals: Germany, the United Kingdom, Liechtenstein and Ireland.
Germany
On March 20, 2023 the German Federal Ministry of Finance published a discussion draft for a law implementing the Directive to ensure a global minimum taxation for multinational corporate groups and large domestic groups in the European Union. The interested professional public is given the opportunity to comment on the discussion draft. The consultation period runs until April 21, 2023. Interested parties can send their input to the following e-mail address Pillar2 @bmf.bund.de.
The text of the discussion draft as released on March 20, 2023 by the German Federal Ministry of Finance can be found here.
The United Kingdom
On March 23, 2023 draft legislation to implement a global minimum taxation for multinational corporate groups and accompanying Explanatory Notes were introduced for a first reading into the House of Commons as part of the Spring Finance Bill.
The draft legislation to introduce a 15% domestic top-up tax can be found in Part 4 of the 2023 the Spring Finance Bill, which starts on page 188. The Explanatory Notes per clause regarding the domestic top-up tax to be introduced in the UK can be found as of page 524 of the Explanatory Notes.
The 2023 the Spring Finance Bill as introduced in the House of Commons can be found here.
The accompanying Explanatory Notes can be found here.
Liechtenstein
On March 29, 2023 the Government of Liechtenstein opened a consultation on draft legislation to implement a global minimum taxation of large multinationals and large Liechtenstein domestic groups. The consultation period ends on June 2, 2023.
The implementation provides for the introduction of a Liechtenstein supplementary tax in the form of an "Income Inclusion Rule" as well as a "Qualified Domestic Minimum Top-up Tax" and an "Undertaxed Payments Rule".
The consultation document containing the draft legislation to implement a global minimum taxation of large multinationals and large Liechtenstein domestic groups can be found here.
Ireland
On March 31, 2023 the Irish Finance Department released a proposed legislative approach to implement the Directive to ensure a global minimum taxation for multinational corporate groups and large domestic groups in the European Union as part of a Feedback Statement it launched as follow-up to its public consultation of May 2022.
Here you can find the Feedback Statement containing the proposed legislative approach to implement the Directive to ensure a global minimum taxation for multinational corporate groups and large domestic groups as Annex 1.
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