As one of the most discussed topics, the Global Minimum Tax (“GMT”) is one of the largest tax reformations as part of the initiative under
Pillar 2 of the Base Erosion Profit-Shifting (“BEPS”) 2.0 project. It subjects multinational companies, with an annual revenue of more
than EUR 750 million in minimum 2 out of the past 4 fiscal years, a minimum tax rate of 15% regardless of their location.
The Pillar 2 Model Rules, also known as Global Anti-Base Erosion (“GloBE”) Rules, were released by the OECD on 20 December 2021 to end
the competition between countries to offer the lowest possible corporation tax rates to attract foreign investments by subjecting
multinational groups around the world to a global minimum tax of 15%.
Our goal is to offer a reliable alternative for transfer pricing needs, delivering proactive, practical, and cost-effective advisory services enhanced by cutting-edge technology.
The ATO has tightened CbC reporting rules for MNEs, effective January 1, 2025, significantly increasing compliance costs and obligations. Key changes include the elimination of most self-assessed exemptions, requiring formal requests with detailed evidence, and reduced administrative relief for local file reporting.
Global Minimum Tax (GMT) is one of the largest tax reformations as part of the initiative under Pillar 2 of the Base Erosion Profit-Shifting (BEPS) 2.0 project.