In the ever-evolving landscape of global tax frameworks, the implementation of Pillar Two rules has been a key focus for many European countries and beyond. Let’s delve into the current status of adoption among EU Member States and other major European countries, as well as the contrasting approach in the United States.
European Union Member States:
1. Eighteen out of the 27 EU Member States have embraced both the Income Inclusion Rule (IIR) and the Quoted Domestic Market Taxation (QDMTT) in 2024, showcasing a proactive approach to international tax reforms.
2. On the flip side, nine EU Member States have yet to implement these rules, highlighting a lag in compliance with global tax standards.
3. Some EU Member States have opted for a six-year deferral of Pillar Two implementation, with all five countries taking this route. Estonia, Latvia, Lithuania, and Malta have deferred all rules until 2029, while Slovakia has selectively implemented a domestic top-up tax in 2024.
4. Four other EU Member States—Cyprus, Poland, Portugal, and Spain—have not fully implemented the Pillar Two rules as required by the EU Directive. Poland, for instance, deferred the implementation by one year, pushing it to 2025.
Major European Countries Outside the EU:
1. Among major European countries outside the EU, only Norway, Turkey, and the United Kingdom have fully implemented both QDMTT and IIR in 2024, demonstrating a commitment to global tax compliance.
2. Switzerland, however, has only implemented QDMTT in 2024 without setting specific dates for IIR or UTPR, indicating a more cautious approach to international tax reforms.
3. Iceland is currently in the process of public consultation regarding the implementation of QDMTT and IIR in 2025, with no concrete plans for UTPR as of now.
4. Countries like Georgia, Moldova, and Ukraine, the latest candidates for EU accession, have not yet declared any intentions to adopt Pillar Two rules, reflecting the complexities of tax policy alignment during the accession process.
United States Stance on Global Tax Deal:
In contrast to many European nations, the US has chosen not to align with the global tax deal, citing challenges in securing bipartisan support for tax treaty ratification. This decision poses risks to the US tax base, particularly in regards to US global intangible low-taxed income (GILTI) and potential reductions in tax revenues.
In Conclusion:
As global tax policies continue to evolve, it is imperative for countries to navigate the intricacies of international tax frameworks while weighing potential impacts on tax revenues and trade relationships. Subscribing to expert insights can help individuals and businesses stay informed on the shifting tax landscape and make informed decisions in response to evolving tax policies. Stay abreast of the developments to ensure compliance and strategic tax planning in a rapidly changing global tax environment.
