The Italian Chamber of Commerce in Hong Kong is pleased to invite you to this insightful seminar "The Pillar Two Model Rules: Ensuring Minimum Taxation for Multinational Enterprises”, in collaboration with Deloitte. The event will be held on September 25th, from 12 pm to 2 pm, at the Italian Chamber of Commerce Office.

The Pillar Two Model Rules are designed to ensure large multinational enterprises (MNEs) pay a minimum level of tax on the income they derive in each jurisdiction where they operate. The Model Rules are a legislation template that jurisdictions are meant to translate into domestic law.

Model Rules are integrated and supplemented by the Commentary and the administrative guidance which have the role to help jurisdictions in implementing the relevant domestic template legislation within the agreed timeframe and in a coordinated manner.

The Pillar Two Model Rules have been designed as an overlay of tax rules which float upon a diverse range of tax systems. As such, many of the specific provisions of the Pillar Two Model Rules will not apply to all jurisdictions or each individual in scope MNE. Taxpayers who are in the scope of the rules compute their effective tax rate with respect to each jurisdiction where they are carrying out business operations and pay top-up tax for the difference between 15% and their effective tax rate.

The eventual top-up tax is generally charged in the jurisdiction of the ultimate parent of the MNE. A de minimis exclusion applies where there is a relatively small amount of revenue and income in a jurisdiction. The Model Rules contemplate the possibility for the jurisdictions to keep their primary right of taxation over its income there generated by introducing their own domestic minimum top-up tax (QDMTT) which must mirror the Model Rules and which prevents (or is at least fully creditable against) any liability under Model Rules.

About the Speaker:

Stefano Grilli is an Adjunct Professor of International Tax Law at the University of Milan Bicocca and a Partner of Deloitte (Milan). Senior Counsel to the Italian Ministry of Finance for the Italian Presidency of G7 (2023-2025) and of G20 (2020-2021) in relation to international tax matters (inter alia Pillar 1 and Pillar 2). He is a member of the Advisory Board of the Belt and Road Initiative Tax Administration Cooperation Mechanism and an “independent persons of standing” as per Art. 9 of the Council Directive (EU) 2017/1852 of 10 October 2017 on Tax Dispute Resolution Mechanisms in the European Union.