Global minimum tax updates

The Inclusive Framework on BEPS has released a compilation of ‘qualified’ domestic rules and tools to streamline the administration of the global minimum tax.

The global minimum tax includes an agreed rule order that limits the application of minimum tax rules in one jurisdiction if there are ‘qualified’ rules in another. In 2024 the Inclusive Framework established a fast-track process to confirm the qualified status of a jurisdiction's domestic legislation on a transitional basis. The recently published Central Record of Legislation with Transitional Qualified Status lists jurisdictions whose minimum tax legislation has completed this process. This record will be updated regularly to include additional legislation that completes the fast-track process.

In connection with the release of the Central Record the Inclusive Framework has provided further Administrative Guidance on Article 9.1 of the GloBE Model Rules which excludes certain deferred tax assets from the computation of an...