Corporate Tax in Tax and Legal blog

Join our insightful breakfast on developments in US inbound investments in Zurich, 10 May 2023


We would like to invite you to join our 2023 US Inbound Breakfast Seminar at our Zurich office on Wednesday, 10 May at 08.30am (CET), where you will gain insight on developments in US inbound investments from Deloitte US & Global Business Alliance CEO, Nancy McLernon.

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Posted on 28/04/2023 | 0 Comments

Join our OECD Pillar II tax accounting seminar in Geneva, 9 - 11 May 2023


We would like to invite you to our OECD Pillar II/GloBE Tax Accounting seminar from Tuesday 9 to Thursday 11 May 2023 in the Deloitte office in Geneva. Over this three half-day workshop series (1pm to 6pm), our team of local tax accounting and Pillar II experts will provide an interactive training taking you from the basics of tax accounting to understanding key considerations of Pillar II.

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Posted on 12/04/2023 | 0 Comments

OECD releases Pillar Two Administrative Guidance


On 2 February 2023, the OECD/G20 Inclusive Framework on BEPS (inclusive framework) released a package of technical and administrative guidance (“administrative guidance”) related to the 15% global minimum tax on multinational corporations known as Pillar Two (or the global anti-base erosion (“GloBE”) rules). The guidance was agreed by consensus of all 142 countries and jurisdictions in the OECD/G20 inclusive framework and forms part of the “common approach.” Under the common approach, countries are not required to adopt the GloBE rules but, if they choose to do so, they agree to implement and administer the rules in a way that is consistent with the outcomes provided for under the Pillar Two model rules and any subsequent guidance agreed by the inclusive framework.

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Posted on 13/02/2023 | 0 Comments

Deloitte Finance Day 2023 - The colours of finance - design your future capability - 1 June 2023 in Zurich

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On Thursday 1 June 2023 in Zurich, Deloitte Finance Day is returning for a second edition. We invite you to experience a unique event to grow your network, share ideas on the future of finance, and hear from industry experts on their journey.

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Posted on 10/02/2023 | 0 Comments

Higher attention to Country-by-Country Reporting going forward


Recent developments, such as the acceleration of the public Country-by-Country Reporting (“CbCR”) obligations by Romania, as well the newly published guidance regarding Pillar II safe harbour rules, have put increasing pressure and scrutiny on Multinational Enterprises’ (“MNEs”) CbCR obligations and will directly affect companies’ tax compliance obligations.

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Posted on 31/01/2023 | 0 Comments

Join our OECD Pillar II webinar on 15 February 2023, 4.00pm


The implementation of the Global Minimum Tax (“OECD Pillar II”) experienced a significant push towards reality in late December 2022, which included:

  • The European Union adopting the directive requiring members to transpose it into domestic legislation
  • Switzerland completing the parliamentary process on its change of constitution
  • The OECD`s publishing a number of papers to guide the GloBE implementation (in particular: safe harbours, information return and tax certainty)

To navigate these developments we are organising a keynote webinar on Wednesday 15, February 2023 from 4.00 to 5.30pm to discuss these and other topics.

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Posted on 25/01/2023 | 0 Comments

South Korea: First Country to pass the domestic Global Minimum Tax legislation

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On 23 December 2022, the Korean National Assembly officially passed the 2022 Tax Revision Bill originally announced by the Ministry of Economy and Finance back in July 2022.

This is a pivotal moment in the advancement of the global minimum tax “Pillar Two” as South Korea is the first country to codify the GloBE Rules into domestic legislation. The newly passed law provides that a global minimum tax will be introduced from fiscal years beginning on or after 1 January 2024.

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Posted on 20/01/2023 | 0 Comments

OECD Pillar Two: Information return and safe harbors published


On 20 December 2022, the OECD published an implementation package in respect of the implementation of the Pillar Two global minimum tax rules (“Pillar Two”). The package includes: guidance on safe harbors; a public consultation document on the GloBE information return (“information return”); and a public consultation document on tax certainty.

This follows the statement on the components of global tax reform, agreed by more than 135 members of the OECD/G20 Inclusive Framework on BEPS (“OECD inclusive framework”) in October 2021, and the publication by the OECD inclusive framework of model rules for Pillar Two in December 2021 and commentary in March 2022.

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Posted on 21/12/2022 | 0 Comments

EU to adopt its “Pillar II” Directive and a clear road to implementation


Looming over taxpayers for most of 2022, the EU-Directive to adopt the global minimum tax in member states has received consent from both Hungary and Poland according to a press release of the EU-Council on 12 December 2022. The formal adoption to finalize the project one year after publication of the initial proposal is expected to take place on 14 December 2022. The EU-Directive expects member states to transpose the directive into domestic law by 31 December 2023. The adoption ends a year-long political back and forth in the EU council and greenlights one of Europe’s most significant overhaul of tax determination of multinational enterprises (“MNE Groups”).

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Posted on 13/12/2022 | 0 Comments

OECD Pillar One – Amount B transfer pricing distribution return


On 8 December 2022, the OECD published a consultation document on the main design elements of ‘Pillar One – Amount B’, outlining a new process for pricing baseline distribution activities in accordance with the arm’s length principle.

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Posted on 13/12/2022 | 0 Comments