New Zealand introduces OECD Pillar Two GLoBE Rules
On 18 May 2023, the New Zealand government introduced details of the planned implementation of the OECD’s Pillar Two Global Anti-Base Erosion (GloBE) rules to Parliament.
While the actual effective date of implementation of the GloBE was not yet fixed, it will not be earlier than 1 January 2024 for the income inclusion rule (IIR) and 1 January 2025 for the undertaxed profits rule (UTPR).
The proposed Bill will also amend the ITA to ensure, in accordance with the OECD’s Inclusive Framework on Base Erosion and Profit Shifting, that the GloBE rules adopted by New Zealand would apply notwithstanding the terms of a tax treaty, unless those terms expressly refer to the GloBE rules.
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