March 19, 2024



Pillar Two Momentum: Greece Advances Global Minimum Tax Frameworks

  • Greece is considering legislation for Pillar Two income inclusion rule (IIR) and undertaxed payment rule (UTPR), along with qualified domestic minimum top-up tax (QDMTT). IIR and QDMTT would apply from 31 Dec 2023, and UTPR from 31 Dec 2024.

Expanding Treaty Networks: New Agreements and BEPS MLI Updates

  • New treaties were signed between Croatia-Hong Kong, Cuba-Turkey, and Estonia-Qatar. All first-time agreements between the respective countries.
  • India-Mauritius sign protocol to amend 1982 tax treaty, details pending. Iran-Tanzania conclude negotiations.
  • Synthesized texts published integrating BEPS MLI changes for the Ukraine-Romania treaty. Covers withholding taxes and other items and applies to various dates.

Navigating Transfer Pricing: Canada’s Comprehensive APA Guidance

  • Canada issues updated guidance on advance pricing arrangements (APAs) in Information Circular 94-4R2. Extensive details on the APA process, documentation and program requirements. Aims to enhance transparency.

Tax Policy Watch: US Budget Proposals, Dubai Bank Tax, Nigeria Levy Suspension

  • Dubai introduces a 20% tax on foreign banks, resulting in an 11% rate after UAE’s 9% corporate tax credit.
  • Colombia adjusts various withholding tax rates for exports and economic activities.
  • Nigeria puts the recently announced expatriate employment levy on hold for further stakeholder consultations.
  • US 2025 budget proposals include raising the corporate rate to 28%, increasing alternative minimum tax, and international reforms to GILTI, foreign tax credits, and interest limitations.


The international tax landscape continues to evolve, with Pillar 2 implementation taking center stage as Greece and Thailand move forward. Concurrently, the expansion of treaty networks through new agreements and BEPS MLI updates reflects ongoing efforts to streamline cross-border taxation. Canada’s comprehensive APA guidance underscores the importance of transfer pricing certainty. Finally, recent developments like Dubai’s bank tax, Nigeria’s levy suspension, and the US budget proposals remind us to monitor domestic tax policy changes that can significantly impact global business.