March 11, 2024



Global Minimum Tax Implementation Advances

  • Thailand launches public consultation on draft legislation introducing Pillar Two income inclusion rule and undertaxed payment rule, aiming for a 15% minimum tax on large MNEs. Domestic minimum top-up tax is also proposed—planned implementation in 2025.
  • Poland announces plan to implement EU global minimum tax directive, adding draft bill to legislative agenda. The specific implementation date is not yet confirmed.
  • Malta publishes detailed guidance on partial Pillar Two implementation. Main IIR and UTPR rules deferred up to six years, but certain provisions and reporting requirements are in effect from 31 Dec 2023 to ensure proper directive functioning.

Tax Treaty Developments

  • Luxembourg approves pending treaty with Cape Verde in Chamber of Deputies. Will apply from 1 Jan of the year after ratification.
  • Updated synthesized text published for Luxembourg-Romania treaty as impacted by BEPS MLI, including 2022 protocol amendments. Applies various dates in 2023-2024. Similar texts were issued for Australia-South Africa, Bulgaria-Denmark, Norway-Poland.
  • New treaties were signed between Bahrain-Hong Kong, Croatia-Egypt, Czech Republic-Montenegro, and Gabon-Turkey.

Transfer Pricing & Dispute Resolution

  • France’s Supreme Court finds certain IP royalties taxed in Tunisia eligible for 20% tax-sparing credit (vs. 15% domestic rate) under the treaty.
  • OECD publishes updated arbitration profiles for the Netherlands and Singapore, settling the MAP process under BEPS MLI.

Other International Tax Development

  • UK Spring Budget replaces the non-dom regime with a residence-based system from 2025. Key corporate measures include multinational group interest deduction limits and R&D tax credits.
  • Laos issues rules for non-resident providers of digital services, and e-commerce to register and remit VAT. Reporting via a new online portal from Aug 2024.
  • Nigeria launches mandatory ‘expatriate employment levy’ of USD 10-15k annually.


Tax authorities are steadily progressing with Pillar Two implementation, with Thailand, Poland, and Malta moving forward with domestic legislation or guidance. In parallel, an active period of treaty negotiation and synthesized text publication, reinforce the post-BEPS emphasis on dispute resolution. France’s court decision on credit for Tunisian royalties and new Swiss TP guidance underscores the enduring importance of traditional international tax rules. Overall, it was a busy week of substantive developments across multilateral and bilateral fronts.