Philippe Ghekiere’s Post

Tax partner Amanda Pedvin Varma is the Contributing Editor for the 2025 chapter on “Transfer Pricing” for Lexology's Panoramic guide (formerly Getting the Deal Through). The chapter provides an overview of the US rules, recent trends, and the role of mutual agreement procedures and advance pricing agreements. In the Global Overview, Amanda discusses the evolving international tax landscape, especially given ongoing OECD initiatives. Read the full chapter and Global Overview at Lexology: https://lnkd.in/e22kfrVr

Three key takeaways from the statement by the Co-Chairs of the OECD/G20 Inclusive Framework: 1. Signing ceremony for the Subject to Tax Rule will be held in Paris on 19 September 2024. 2. Negotiations on the text of the Multilateral Convention (MLC) for Amount A is nearing completion, with the goal to open the MLC for signature by the end of June. 3. The negotiations on the framework for Amount B is also nearing completion. https://lnkd.in/gDgQN8kn

On 9 October 2024, Luxembourg’s government introduced its 2025 draft Budget law (number 8444) to the Luxembourg Parliament, referred to as the Draft Law. This Budget aims to make Luxembourg’s economy more competitive, strengthen its financial centre, and improve the purchasing power of households. In this article, we explore the key tax changes proposed in the Budget and what they mean for individuals and businesses. https://lnkd.in/dTg_c-aY

📢 On December 20, 2023, Luxembourg implemented the EU Directive 2022/2523, establishing a 15% minimum tax rate for large multinational and domestic groups in the EU with a consolidated revenue of at least EUR 750 million (referred to as the Pillar Two Law). This legislation could impact the preparation of notes in the annual accounts under Luxembourg Generally Accepted Accounting Principles (LUX GAAP) for financial years beginning no later than December 30, 2023, prompting the Luxembourg Accounting Board to issue clarifying Q&As, including information on the Pillar 2 Law's impact and the option to disclose deferred tax assets and liabilities in the 2023 annual accounts. Get the details in our #PwCFlash 👉 https://ow.ly/lGpb50QNMAe #PillarTwo #TaxLaw

Law 5100/2024 that came into force on 5 April 2024, transposes into Greek law Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the EU. The Directive had converted into EU law the Pillar Two Global Anti-Base Erosion Rules developed by the OECD as part of addressing the tax challenges arising from the digitalisation of the economy in the context of the OECD/G20 Base Erosion and Profit Shifting Project.   Delve into our latest Tax & Accounting newsletter for a comprehensive overview of the recent developments.   bit.ly/3JoCIzR   #zeposyannopoulos #zeyanewsletters

If you look at all the Pillar 2 documents it is fascinating to see that the quality of approval is very different (the screenshots below are taken from p. 2 of all these documents), e.g.: 🔊 Minimum Tax Implementation Handbook --> "work is published under the responsibility of the Secretary-General of the OECD" 🔊 Model Rules/Admin. Guidances --> "approved by the Inclusive Framework" 🔊 Illustrative Examples --> "prepared for publication by the OECD Secretariat" 🔊 Consolidated Commentary --> ??? To be clear here: we are pushing the most important harmonization project in the history of the international tax regime with rather unclear governance rules. The Secretary-General of the OECD seems to have a role, the secretariat of the OECD but also the Inclusive Framework. However, the latter is not an international organization nor has it published any rules of procedure. So from an outsiders perspective it is unclear how these decisions are made. This will lead to quite some chaos - in particular in countries with a direct reference to these documents in their domestic law such as my own country Switzerland. Which of these documents have now become part of domestic law? Only the documents of the Inclusive Framework? All documents? In what language and which version? It is even more challenging for non-OECD countries. #Pillar2 #internationataxpolicy

here, there is a discussion that the new regulation is based in an international law. As If the Brazilian law stopped to be the primary law source. Interesting.

A very interesting thought. For ease of reference, as tax consultants we always refer to OECD as the body carrying out the work. But whether all these myriad documents being released really have the proper level of approval or not may be debatable. Is this one of the reasons why developing countries feel they do not have an effective seat at the table? Is this why they are pushing for UN level discussions?

Forvis Mazars released its latest CEE Tax Guide, providing comprehensive insights into the tax systems of 22 European and 3 Central Asian countries. The report offers guidance to investors exploring market opportunities in these regions by analysing trends in tax burdens, wages, and inflation. This year’s issue also addresses the introduction of the global minimum tax, a pivotal change in international taxation. 👉 Read more info here: https://bit.ly/3VUgThF.  Cc: Edwin Warmerdam, Bianca Vlad, Lucian Dumitru, LLM, Liviu Mihai Gheorghiu. #forvismazarsinromania #fiscalnews 

Transposition of Pillar Two rules in Greek legislation - EU Minimum Tax Directive Find out more in our Tax & Accounting newsletter 👇 #pillar2 #minimumtax #zeya