1. IntroductionThe global minimum tax (Pillar Two) was implemented in the European Union in December 2022 through Directive (EU) 2022/2523 . At its core lies a system of “top-up tax” whereby the…
The GloBE Model Rules have introduced the Qualified Domestic Minimum Top-Up Tax (QDMTT) into the ruleset of the international compromise on an effective minimum tax (“Pillar 2”). A QDMTT is defined…
