24 Jan 2023
Will 2023 Be the Year for a 15% Global Minimum Tax on Multinational Enterprises?
In the last few years, the Organisation for Economic Co-operation and Development (OECD) has discussed a more permanent and effective plan to change tax rules for large companies and limit tax avoidance planning by multinationals, adopting a two-pillar solution. Pillar 1 is focused on changing where companies pay taxes. Pillar 2 would establish a global minimum tax. It’s likely that more countries will adopt Pillar 2 in 2023, requiring those with global revenue above $797 million (€750 million) to pay a minimum 15% tax in each country where they operate.
Related Content
- OECD: Pillar Two Model Rules for Domestic Implementation of 15% Global Minimum Tax
See model rules that OECD published in December 2021 to assist with the implementation of a reform to the international tax system—a reform intending multinational enterprises to be subject to a minimum 15% tax rate, effective from 2023.
Practical Guidance Updates
Featuring the latest updates from your Practical Guidance account.
- Tax Key Legal Developments Tracker (Federal)
Stay informed on new developments:- Business Entities. IRS and Treasury correct final regulations regarding special enforcement matters published in 87 Fed. Reg. 75,473 (Dec. 9, 2022). The correction contains final regulations that except certain partnership-related items from the centralized partnership audit regime created by the Bipartisan Budget Act of 2015 and sets forth alternative rules that will apply to the examination of excepted items by the IRS. Treatment of Special Enforcement Matters; Correction, D. 9969, 88 Fed. Reg. 755 (Jan. 5, 2023); 88 Fed. Reg. 756 (Jan. 5, 2023).
- Practice, Procedure and Controversy. IRS updates procedures for furnishing technical advice thereby superseding Rev. Proc. 2022-2. Rev. Proc. 2023-2.
- Document alerts allow you to stay current on legal developments that affect your practice. Find out how to set up your document alerts.
- The Practical Guidance Journal Climate Change Special Edition features guidance on insuring for climate change, renewable energy initiatives, and a guide for public and private projects related to sea level rise.
- Legal Developments provide the latest updates and analyses of emerging topics impacting your practice area. Visit the Legal Developments page to see the latest topics, which also include breaking legal news and related Practical Guidance content.
- Listen Up! The Practical Guidance and Law360 Podcasts Resource Kit features interviews with industry-leading attorneys on cutting edge issues in the law: NFTs, Cannabis, COVID-19, and more.
- Check out the new Practical Guidance Author Center! Learn about the 1750+ leading attorney authors contributing to our 22 practice areas and find out how you can Become a Practical Guidance Author.
- New and Recently Updated Practical Guidance Content
- KPMG report: Analysis and Observations on Initial Guidance on New 1% Stock Repurchase Excise Tax
- KPMG report: Accounting Method Changes to R&E Expenses under Rev. Procs. 2023-8 and 2023-11
- Tax Enforcement: A Spotlight on Complex Partnership Structures
- SECURE 2.0 Impact on Retirement Plan Compliance and Administration
- IRS Delays $600 Payment Reporting Requirement for 1 Year
- Top Federal Tax Cases of 2022
- Legalization: The Perils, Pitfalls and Promise of Cannabis Podcast
Experience results today with practical guidance, legal research, and data-driven insights—all in one place.
Experience Lexis+