Emerging Jurisdictional Responses and Tax Policy Shifts
In response to Pillar Two, jurisdictions are adjusting domestic tax laws to retain competitiveness while complying with GloBE standards. Some countries have adopted or announced “Qualified Domestic Minimum Top-up Taxes” (QDMTTs), which allow them to collect the top-up tax domestically before it is claimed by other jurisdictions under the IIR or UTPR.
For example, Australia introduced legislation in 2023 for a QDMTT effective in 2024, ensuring any top-up tax owed by Australian subsidiaries of MNEs is paid locally.… Read more