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Canada’s Global Minimum Tax Act substantively enacted as part of Bill C-69 On 19 June 2024, Bill C-69, Budget Implementation Act, 2024, No. 1, received third reading in the House of Commons and became substantively enacted for Canadian financial reporting purposes. Among other measures, Bill C-69 includes a revised version of Canada’s Global Minimum Tax Act (GMTA), which was previously released for public comment last August. In this Tax Alert, we review certain key differences contained in the revised version of the GMTA. Learn more in our latest Tax Alert, Canada’s Global Minimum Tax Act substantively enacted as part of Bill C-69. Click here to view other recent Tax Alerts and follow us on LinkedIn: @EYCanada.

Wealth and corporate taxes remain a sticking point between countries at the U.N. negotiating the roadmap for a framework convention on tax. The first round of talks to establish the parameters of the convention concluded last month. Read the story:

The Australian Parliament's introduction of the global minimum tax bill is a major milestone as BEPS Pillar Two comes into play. This crucial step brings MNEs closer to navigating the changing global tax landscape and planning compliance strategies. Stay updated on the latest announcements and future impacts by reading more below! https://lnkd.in/g4usa_CB

The Australian government has published a draft legislation to enact significant elements of Pillar Two of the OECD/G20 global tax reforms. The A&M Australia Tax team, give an outline of the draft legislation and consultation document, detailing how they aim to enforce the worldwide minimum tax regulations laid out by the OECD. Discover more: https://okt.to/mzPD9t #AustraliaTax #InternationalTax #PillarTwo

On June 20th, 2024, Bills C-59 and C-69 received royal assent. Both bills contain various material amendments to the Income Tax Act (Act) and additionally introduce new legislation based on areas of concern identified by the OECD, namely the Digital Services Tax Act and the Global Minimum Tax Act. Read on the learn more about how the middle market is impacted by these changes.

OECD Pillar 2 Tax Reforms: An increasing number of countries are implementing the GloBE Rules and putting in place a minimum effective tax rate of 15%. To learn more about these reforms and the disputes that might arise, see our post with Robert Denison. Stay tuned for our next post about possible investor-State tax disputes. https://lnkd.in/dxuE-W-F. #Lalive OECD - OCDE

International tax reform: OECD/G20 Inclusive Framework on BEPS taking further steps on the implementation of the Two-Pillar Solution

📄 Submission: International taxation – global and domestic minimum tax – primary legislation Our Tax Policy and Advocacy Team recently made a submission to the Treasury in respect of its consultation on the draft legislation package that proposes to implement key aspects of Pillar Two of the Organisation for Economic Co-operation and Development’s (OECD’s) two-pillar solution as set out in the Global Anti-Base Erosion Rules (GloBE). In particular, the draft legislation package proposes to implement the Domestic Minimum Tax, Income Inclusion Rule, Undertaxed Payments Rule, and domestic top-up tax. These changes, when legislated, will result in significant changes to the compliance obligations for impacted entities. Given the significance of this impact, we consider it important to ensure that the implementation of Pillar Two considers the cost of the additional compliance obligations on taxpayers, and seeks to minimise these costs where opportunities arise to reduce them. We also consider that a Constituent Entity’s obligations in relation to the Australian Globe Tax Return should be satisfied if it has been lodged with another foreign government agency. You can read the full submission below, and we've outlined some further considerations here: ⚫ Further consideration and potentially consultation is required regarding the interaction between Pillar Two and Australia’s tax consolidation regime ⚫ Further consideration should be given to whether entities that are subject to the top-up taxes should also be subject to the various integrity measures that form part of the Inclusive Framework on Base Erosion and Profit Shifting (BEPS) actions already in place in Australia ⚫ Unintended timing issues with respect to the interactions between Pillar Two and the foreign income tax offset rules should be rectified ⚫ The start date for Pillar Two should be delayed by at least 12 months to allow taxpayers reasonable time to understand and meet their tax liabilities ⚫ A prompt post-implementation review of Pillar Two in Australia will be required to ensure that unforeseen issues are rectified in a timely manner ⚫ The approach to non-lodgment penalties should be reviewed, removing the unfair approach of potentially subjecting an AMG to multiple and significant penalties ⚫ The definitions and terminology used in Australian legislation and the contents of information to be requested by the relevant compliance documents/returns should be consistent with the OECD’s approach Let us know what you think below 👇 #TheTaxInstitute #TTI #tax #thehomeoftax #jointhetaxconversation #TaxPolicyandAdvocacy #submission #PillarTwo #OECD #BEPS

The OECD global tax deal has long suffered implementation delays, and will continue to do so in 2024. Learn more about the challenges facing the tax deal in our latest article: https://lnkd.in/eX9YNGkA

INTERNATIONAL TAX PLAZA - 2 Tax items are on the provisional agenda for the ECOFIN Council meeting of May 14, 2024 The next meeting of the Economic and Financial Affairs (ECOFIN) Council is taking place on May 14, 2024. The Agenda highlights and a provisional agenda for this meeting have been published on the website of the European Council/the Council of the EU. The following 2 tax items are mentioned on the provisional agenda. But again the proposal for an unshell Directive is not mentioned on the provisional agenda. https://lnkd.in/emyM3ehA