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This article will answer the following questions:
- What is the purpose of the regulations introduced by Pillar 2?
- Which taxpayers are subject to the global minimum tax?
The new regulations on the global minimum tax will become effective on 1 January 2025. The clock is ticking thus we encourage you to take a moment to fill in a brief questionnaire that will help you find out if the top-up tax law will affect your business in terms of 2024 or 2025.
A detailed analysis of the Pillar 2 regulations allowing to determine if a business is subject to the new regulations is key for budget, time and resource planning, which is necessary when launching well-targeted operations. Taking the right steps early will allow financial departments to collect data that is essential for computing global or domestic minimum tax as well as establishing whether there is an actual obligation to pay it. A proactive approach – that our interactive form will help with – will allow you to steer clear from any unnecessary disruption to your daily operations and brace for the upcoming changes.
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Pillar 2 – what is the purpose of global minimum tax?
Please be reminded that the implemented regulations are aimed at counteracting base erosion profit shifting and forcing global corporations to pay their share of taxes where the effective tax rate in a jurisdiction of a given group’s operation falls below 15%.
The draft act implementing global minimum tax stipulates the introduction of three types of top-up tax:
- global top-up tax – IIR;
- domestic top-up tax – QDMTT;
- top-up tax on undertaxed profits – UTPR.
The regulations implementing top-up tax should have been implemented at the beginning of 2024. Failure of the Polish legislative to meet this obligation does not mean, however, that the new law will not affect Polish businesses as international capital groups from countries where the regulations of the Pillar 2 Directive have been already implemented (e.g. from Austria, Belgium or France), having subsidiaries in Poland, will have to calculate the effective tax rate in Poland for 2024, This imposes on all companies within a group the obligation to collect a great amount of detailed data.
Therefore, the sooner you verify whether your company (companies) is obliged to pay the tax, the better you will be prepared for the changes that are now drawing closer.
Who is subject to top-up tax?
In our previous articles we have indicated the entities subject to the new tax, as well as those exempt from it.
Below you will find an interactive questionnaire that will help you determine if the new regulations on top-up tax will apply to your business.
We strongly encourage you to take a moment to fill it in to find out today whether your company (or companies) will be obliged to pay the new tax.
Please be aware that the questionnaire does not cover joint or split groups.
Should you have any questions or feel the need to discuss the subject in detail, we strongly encourage you to contact our experts. They will be happy to support you in the process of reviewing matters related to global minimum tax – starting from finding out whether it applies to your business, all the way to determining the exact amount of tax payable. We are at your disposal.
