March 4, 2024



Countries Progress Implementation of Global Minimum Tax

  • Malta published a Legal Notice partially transposing the Pillar Two Directive, including definitions and reporting rules but deferring main IIR and UTPR rules. Deferral allowed for a maximum of six fiscal years from 31 Dec 2023—local filing requirements mandated unless filed by an ultimate parent or designated filing entity in another qualifying EU jurisdiction.
  • Senegal requires CbC reports to be submitted electronically using specified forms, with content/format aligned with OECD standards.
  • Bahamas announced Pillar Two qualified domestic minimum top-up tax (QDMTT) will be introduced with a 15% rate on large MNE groups. Draft legislation is expected by May 2024, with an estimated $140 million in additional annual revenue. 
  • Greece is consulting on legislation for the Pillar Two Global Minimum Tax, aiming for a 15% minimum tax level for multinational enterprise (MNE) groups.

 VAT and Service Tax Adjustments

  • Ecuador is increasing its VAT rate from 12% to 13% starting April 2024, with a potential further increase to 15%, to strengthen security amid rising violence.
  • Malaysia is raising its service tax rate from 6% to 8% for foreign digital service providers, effective March 1, 2024.

International Agreements and Cooperation

  • The Czech Republic and Malta are set to sign a new income tax treaty, replacing the one from 1996.
  • India and Mauritius plan to sign a tax treaty protocol, showcasing efforts to update international tax agreements for mutual benefit.

Domestic Tax Reforms

  • Switzerland is adopting a dispatch on individual taxation reform to transition from joint to individual taxation, addressing the “marriage penalty” and incentivizing employment.
  • India’s Finance Act 2024 includes limited tax measures such as exemptions and extensions to support financial services, startups, and international investment.

Tax Transparency and Exchange of Information

  • Singapore updated its CbC report exchange relationships to include Papua New Guinea, enhancing tax transparency.
  • The OECD Global Forum launched a Model Manual for CRS Compliance Audits, supporting jurisdictions in developing and implementing their administrative compliance strategies.


As countries continue implementing global minimum tax rules, we also see counterbalancing measures like incentives and tax benefits maintained or expanded. This indicates a delicate balance tax authorities must strike between collecting revenue and encouraging investment. Heightened information exchange facilitates enforcement, but may risk capital flight without corresponding benefits.