Malta Tax Agency Issues Guidance Note on EU Global Minimum Taxation for Large MNEs

The Maltese Commissioner for Revenue Feb. 28 issued a guidance note on the transposition of EU Directive 2022/2523, on a global minimum 15 percent level of taxation for covered multinational enterprise (MNE) groups and large-scale domestic groups in the EU, under Pillar Two of the OECD/G20 base erosion and profit shifting (BEPS) project. Topics covered include: 1) clarification that Malta has notified the EU Commission of its election to delay application of the income inclusion rule (IIR) and the undertaxed profits rule (UTPR), for a maximum period of six consecutive fiscal years beginning from Dec. 31, 2023; and 2) clarification ...