Jurisdiction | Legislation | Comments |
Antigua & Barbuda | | Overview: Antigua & Barbuda is in the process of implementing Pillar Two legislation. On 26 Feb 2025, the Ministry of Legal Affairs, Public Safety, and Labour published draft legislation, the Base Erosion and Profit Shifting (BEPS) Bill 2025, that would fulfill Antigua & Barbuda’s commitment to implement the Pillar Two initiative. The draft focuses on CbCR and transfer pricing and would require MNEs with annual revenues exceeding EUR 750 million to submit a CbC report to the Inland Revenue Department, comply with other filing obligations and require related party transactions to be in line with the arm’s length principle. If approved, the CbCR provisions would become effective for accounting periods ending on or after 31 Dec 2024 and the remaining provisions would take effect on 1 Jan 2026. |
Australia | Minimum Tax Law | Overview: The three bills that implement the EU Pillar Two directive into Australian legislation were passed by parliament and received royal assent on 10 Dec 2024, as a result of which the measures are enacted. On 23 Dec, the government published subordinate legislation, the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024, which sets out how the global minimum tax will be applied, addressing issues such as computation of GloBE income or loss, adjusted covered taxes, the ETR, safe harbours, etc. Australia has introduced an IIR, a UTPR and a DMTT. The IIR and DMTT apply to large MNEs with Australian operations for fiscal years starting on or after 1 Jan 2024, while the UTPR applies for fiscal years starting on or after 1 Jan 2025. A consultation opened on 26 Oct 2025 on draft legislation that would amend the Pillar Two rules, including the introduction of an equity investment inclusion election, rules on qualified flow-through tax benefits and rules on securitization entities. The consultation closes 21 Nov. According to an explanatory statement accompanying the draft legislation, the amendments would ensure that OECD guidance is incorporated appropriately into Australia’s Pillar Two legislation. The ATO has released several sets of guidance on the Pillar Two rules: - Guidance published on 17 Dec 2025 focuses on the application of the rules to tax-consolidated groups with respect to top-up tax calculations, filing requirements and reporting simplifications. This release was accompanied by updates to the following earlier published guidance:
- Global and domestic minimum tax
- When and how the Pillar Two rules apply
- Lodging, paying and other obligations for Pillar Two
- Transitional CBC reporting safe harbour
- Specific issues for Pillar Two
- Guidance released on 4 Nov 2025 confirms that the domestic hybrid mismatch rules will continue to apply despite the implementation of the Pillar Two framework, a clarification relevant for MNE groups navigating both regimes. The update addresses the meaning of the phrase “subject to foreign income tax” in the context of hybrid mismatch rules and clarifies that foreign GloBE tax is to be disregarded when assessing whether an amount is subject to foreign income tax for hybrid mismatch purposes.
- New guidance on the transitional CbC reporting safe harbour, published on 20 Oct 2025, addresses the conditions for applying the safe harbour and how to apply the transitional CbC reporting safe harbour tests.
- A ruling dating from 2006 has been updated to address the ability of taxpayers to obtain private rulings on interpretative issues relating to Pillar Two and on the new Pillar Two “decline to rule” provision.
Australia’s IIR and DMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: In-scope Australian entities must file four returns: - The GIR, a standardized OECD form with information about the group, which is required to calculate the liability;
- Foreign notification form, an annual notification in which the ATO is notified that a foreign entity has filed the GIR on behalf of an Australian entity and the jurisdiction;
- The Australian IIR/UTPR return; and
- The Australian DMTT return.
The latter two returns, which are Australian domestic tax returns, are being developed by the ATO to enable the triggering of Australia's domestic assessment and pay provisions, as is the foreign lodgment notification. The three forms are expected to be combined into a single form. The ATO has released sample forms. The default requirement is for each Australian group entity in an MNE group to file a GIR, although another group entity may be designated to file a single GIR on behalf of the group. This can be a designated local entity filing with the ATO, a foreign UPE or a designated filing entity filing with a foreign government. All four returns must be filed within 15 months after the end of the fiscal year (18 months for the first fiscal year). A draft legislative instrument released for consultation by the ATO on 27 Aug 2025 would exempt MNE groups from filing IIR, UTPR or DMTT returns if no tax is due and certain requirements are met. While those returns would not have to be filed in situations where top-up tax amounts would always be nil, the GIR would still have to be filed as would any foreign notification where the GIR is filed in a foreign country. On 26 Nov 2025, the ATO finalized guidance on its approach to enforcing penalties relating to filing obligations for the minimum tax during a “transition period.” The final guidance, which is unchanged from the draft version, applies retroactively as from 1 Jan 2024 to filings made relating to fiscal years starting on or before 31 Dec 2026 and ending on or before 30 Jun 2028 (the transition period). |
Austria | Minimum Taxation Act | Overview: The Minimum Taxation Act, which transposes the EU global minimum taxation directive into Austrian law, was published on 30 Dec 2023 and became effective on 31 Dec 2023. The Tax Amendment Act 2024, which became effective on 20 Jul 2024, makes minor changes to the legislation, which have been consolidated into the act. A regulation published on 5 Dec 2024 provides additional clarifications on the CbCR safe harbours. The Pillar Two legislation includes the introduction of an IIR and a UTPR, and Austria has elected to adopt a QDMTT (referred to as a “national supplementary tax”) as provided in the directive to ensure a 15% minimum tax on Austrian resident entities on a consolidated basis. The IIR and QDMTT apply for fiscal years starting on or after 31 Dec 2023 and the UTPR applies for fiscal years starting on or after 31 Dec 2024. Austria has adopted all of the safe harbours (i.e., temporary CbCR safe harbours, permanent safe harbour for non-material constituent entities, QDMTT safe harbour and temporary UTPR safe harbour). Austria’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. The draft Tax Amendment Act 2025 that will make various revisions to the domestic Pillar Two rules has been approved by the government but still needs to be approved by parliament and published. On 27 Jun 2025, the Ministry of Finance published FAQs on the application of the Minimum Taxation Act, which address the scope of application, safe harbours, transitional provisions and entry into force. Previous FAQs were published on 20 Jun 2024. Notification/Filing: Austria has a notification requirement and in-scope entities must file a GIR and top-up tax return. Pillar Two tax liability is concentrated in a single Austrian CE (called the “central taxpayer”). The UPE has the primary right to designate an entity in Austria to file and pay tax on behalf of the MNE group for all Austrian entities. Proof of such an appointment (i.e., a PDF letter of intent signed by a representative of the UPE) is to be uploaded by the appointed Austrian CE to the FinanzOnline website. Such an appointment must be made before the end of the calendar year in which the relevant fiscal year ends. If no appointment is made, the filing obligation automatically falls on the highest group entity located in Austria or, if there is no top CE in Austria, the most economically significant CE in Austria. Each CE in Austria is required to file a GIR but if an MNE group has multiple Austrian CEs, a designated local entity can be appointed by the other CEs to file the GIR on their behalf. A GIR is not required if the return is filed by the UPE or designated filing entity located in a jurisdiction that has concluded a qualified competent authority agreement with Austria for the relevant year. The GIR must be filed within 15 months from the end of the relevant fiscal (18 months in the first year of application) but not before 30 Jun 2026). The central taxpayer must file the top-up tax return and pay the top-up tax by 31 Dec of the second calendar year following the year in which the relevant fiscal. BDO Insights https://www.bdo.at/en-gb/insights/tax-news/pillar-two#:~:text=The%20UPE%20may%20appoint%20any,until%20the%20end%20of%202025 |
Bahamas | Domestic Minimum Top-Up Tax Act | Overview: The Domestic Minimum Top-Up Tax Act, which introduces a DMTT in the Bahamas, was enacted on 18 Nov 2024 and applies retroactively as from 1 Jan 2024. The QDMTT allows the country in which low-taxed group entities are located to impose the top-up tax. The legislation is based on the OECD GloBE Rules, and the OECD administrative guidance is applicable. The Bahamas is not introducing an IIR or a UTPR. The legislation applies to fiscal years of an MNE group that begin after 31 Dec 2023 where all CEs in the Bahamas would be subject to an IIR or a UTPR in another jurisdiction. For all other MNE groups, the DMTT applies for fiscal years that commence after 31 Dec 2024. The act has been amended retroactive to 1 Jan 2024 to repeal the business license exemption for in-scope entities and allow businesses to credit their business license tax payments against the DMTT due for the fiscal year their business license expires. It should be noted that before the enactment of the Domestic Minimum Top-Up Tax Act, the Bahamas did not levy corporate income tax on businesses; instead, they paid a Business Licence Tax on their gross revenues. A bill presented on 28 May 2025 (the Business Development Incentives Programme Bill, 2025) would grant financial incentives to encourage investment activities that contribute to the economic welfare of the Bahamas and enhance its global competitiveness. The measures are expected to meet the requirements of refundable tax credits in line with the Pillar Two rules. Notification/Filing: The Bahamas has registration and notification requirements and also requires in-scope entities to file a GIR and a top-up tax return. The prime minister announced on 3 Dec 2025 that registration for the DMTT will commence in early 2026 for in-scope entities. Where an entity falls within the scope of the DMTT, it must file the GIR or have the GIR filed on its behalf. Any DMTT due must be paid no later than the day that is 15 months after the last day of the relevant fiscal year (18 months for the first year of application). |
Bahrain | Decree Law No. 11 of 2024 | Overview: A decree law (Decree Law No. 11 of 2024) announced on 1 Sept 2024 introduced a domestic minimum top-up tax (DMTT) in Bahrain. Executive Regulations (accompanied by a guide and FAQs) released by the National Bureau of Revenue (NBR) on 15 Dec 2024 provide detailed rules for the operation of the DMTT; these rules are generally in line with the OECD GloBE rules. The decree law, which applies to fiscal years starting on or after 1 Jan 2025, provides for a DMTT, but no IIR or UTPR. The DMTT allows the country in which low-taxed group entities are located to impose the top-up tax. It applies to Bahrain-based CEs of an MNE group whose annual group revenue equals or exceeds EUR 750 million in at least two of the four preceding fiscal years. The decree law also contains safe harbours and a general anti-avoidance rule. The NBR has published several sets of additional guidance: - Guidance released on 16 Jan 2025 addresses the application of the DMTT and Executive Regulations, including information on how the DMTT operates, revenue thresholds, exclusions, compliance rules and transition measures. This guidance was updated on 1 Dec 2025 to address the registration of newly established entities and clarify the computation of the registration deadline.
- The NBR published another guide on the administration of the DMT on 15 May 2025, which addresses operational, procedural and compliance obligations for in-scope MNEs.
- On 2 Jul 2025, the NBR published a manual for CEs to use when making advance payments of the DMTT.
- The NBR published an updated guide on 12 Aug 2025, Entities in Scope of DMTT and an updated DMTT Advance Payment Manual.
A committee has been set up to oversee DMTT-related objections and ensure fair application of the rules and a fee structure governing tax appeals relating to the DMTT has been established, i.e., a fee of BHD 50 will be imposed for each request for review submitted to the NBR and a fee of BHD 100 will apply to each formal appeal lodged before the Tax Appeals Committee. Notification/Filing: There are registration and notification requirements and a top-up return filing obligation. An MNE group with covered entities located in Bahrain must appoint a filing CE that will be responsible for completing the registration, filing the tax return and paying the tax due. Registration must be completed within 120 days from the first day of the fiscal year in which the MNE group falls within the scope of the Pillar Two rules. The NBR has clarified that for entities incorporated in Bahrain on or after 1 Jan 2025, the 120-day deadline begins from the date the entity obtains "Active with License" status in the Commercial Register. The filing CE will receive a registration certificate if the NBR accepts the application. Any changes to the information must be updated within 30 days of the change. The DMTT registration manual provides step-by-step instructions on the registration process, including how to use the NBR’s online portal for DMTT compliance. The tax return contains an “information schedule” that will have information on CEs outside Bahrain. If that schedule is submitted by the UPE or a designated entity located in a jurisdiction with a qualifying competent authority agreement with Bahrain, the tax return has to include the identity and location of the entity that filed the schedule. The top-up tax return must be filed by the relevant CE and tax due paid through quarterly advance payments. The quarterly payments must be made within 60 days after the end of the relevant quarter, with the balance paid within 15 months from the end of the relevant fiscal year. The Ministry of Finance and National Economy has introduced a fee structure for tax appeals relating to the DMTT. Other: Bahrain is the first Gulf Cooperation Council country to implement a DMTT. BDO Insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/bahrain-new-fee-structure-for-dmtt-appeals-and-guidance-on-the-minimum-tax https://www.bdo.global/en-gb/insights/tax/world-wide-tax/bahrain-domestic-minimum-top-up-tax-to-apply-in-2025 |
Barbados | Corporation Top-up Tax Act, 2024 | Overview: The Barbados Corporation Top-Up Tax (Amendment) Act 2024 was signed by the president on 21 May 2024 and published in the official gazette on 24 May. The legislation introduces a 15% domestic minimum top-up tax (DMTT) that applies for fiscal years starting on or after 1 Jan 2024. A carve-out applied in 2024 where the top-up tax applied only if the income of the Barbados group was subject to an IIR or UTPR in another jurisdiction. The legislation does not include an IIR or a UTPR. The QDMTT "tops up" the tax paid in Barbados to ensure that the minimum 15% ETR is met and that profits earned in Barbados are subject to at least the minimum level of taxation. The legislation provides for the application of the transitional CbCR safe harbour. Barbados’ QDMTT is treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: Barbados has a registration requirement but no notification of filing requirement and a QDMTT return must be submitted. A resident CE must notify the tax authorities that it is a covered entity within 12 months after the last day of the first fiscal year the entity becomes a qualifying entity. The tax authorities will designate the form and manner for the notification. Any change to the information initially provided, including where an entity ceases to be a CE, must be provided to the authorities within 12 months of the end of the fiscal year in which the change took place. An in-scope entity must submit a QDMTT return in the form and manner specified by the Commissioner, taking into account the GloBE Model Rules on filing obligations, on or before the specified return date. |
Belgium | Law concerning the introduction of a minimum tax for multinational enterprise groups and large national groups | Overview: The bill transposing the EU global minimum taxation directive into Belgian law was published on 28 Dec 2023 and became effective on 31 Dec. A law approved by parliament on 2 May 2024 and published on 29 May transposes the OECD’s administrative guidance into domestic law and corrects some implementation errors. Belgium’s Pillar Two legislation includes an IIR and a UTPR, and the country has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Belgian resident entities on a consolidated basis. The IIR and QDMTT apply for fiscal years starting on or after 31 Dec 2023 and the UTPR applies for fiscal years starting on or after 31 Dec 2024. Belgium’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Guidance released on 22 Oct 2025 addresses various aspects of Belgium’s implementation of the EU directive, including scope, determination of GLoBE income, calculation of adjusted covered taxes, the ETR and top‑up taxes, collection of tax, etc. A draft bill submitted to parliament on 9 Oct 2025 contains technical amendments to Belgium’s Pillar Two legislation, including a requirement for in-scope companies to appoint a general representative who would be responsible for compliance, a new definition of “group,” a reduction of the assessment/tax audit period from 10 to six years and some clarifications. A decree released on 19 Jan 2024 that applies retroactively as from 1 Jan 2024 announced a service for taxpayer questions about the application of the legislation. Notification/Filing: Belgium has registration and notification requirements and in-scope entities must file a GIR and a top-up tax return. In-scope groups with a Belgian CE must register with the Crossroads Bank for Enterprises to identify the group for Pillar Two purposes and to receive a unique ID number for compliance purposes. Registration must be completed no later than 30 days after the start of the tax year for which the MNE group or the large-scale domestic group falls within the scope of the minimum tax rules. If the GIR is not filed locally, a notification of the filing entity must be submitted to the tax authorities. On 21 May 2024, the tax authorities released guidance relating to the Pillar Two notification requirement. A specific notification form had to be submitted by 13 Jul for Pillar Two reporting periods that started between 1 Jan 2024 and 13 Jun 2024. If the first Pillar Two reporting period starts after 13 Jun 2024, the notification deadline is 30 days after the start of the first Pillar Two reporting year. Belgian CEs must file a GIR within 15 months from the end of the relevant fiscal year (18 months for the first year). If there are multiple Belgian CEs, one entity can be designated to file the GIR on behalf of all Belgian CEs. However, a GIR is not required if the return is filed by a UPE or designated filing entity located in a jurisdiction that has entered into a qualifying competent authority agreement with Belgium that is in effect for the relevant year. Each Belgian CE (or designated CE) must file a top-up tax return. The government published a draft updated QDMTT return on 10 Apr 2025 (that is aligned with the GIR template) and draft XML schema definition files related to the return form on 24 Jun 2025. Groups will have to be registered in Belgium to submit the QDMTT return. The tax administration announced on 17 Nov 2025 that the deadline for filing the annual QDMTT return for fiscal years starting on or after 31 Dec 2023 and ending on or after 1 Jan 2024 (and no later than 30 Jun 2025) is extended to 30 Jun 2026 (the original deadline was 30 Nov 2025). The authorities have not finalised the tax return template and XSD scheme nor released technical guidance on the completion of the return; the announcement does not provide details on when these documents will be released. The revised deadline applies to all QDMTT returns for which the original filing date would have fallen before 30 Jun 2026.
Other: On 17 Jul 2025, the Belgian Constitutional Court issued its decision in a case brought by US-affiliated business groups in 2024 challenging the compatibility of the UTPR under the EU Minimum Tax Directive with EU fundamental rights and freedoms. The US groups take the position that the UTPR imposes disproportionate tax burdens on Belgian entities for profits earned by foreign group members, potentially violating the principles of legal certainty, nondiscrimination and the freedom to conduct business. The Belgian court has referred the case to the Court of Justice of the European Union for a preliminary ruling. |
Bermuda | Corporate Income Tax Act 2023 | Overview: A law published in the official gazette on 28 Dec 2023 introduced a corporate income tax and contains a 15% tax on Bermuda businesses that are part of MNE groups with annual revenue of EUR 750 million or more. Bermuda does not intend to introduce an IIR or a UTPR. The legislation applies to tax years starting on or after 1 Jan 2025. The Ministry of Finance released FAQs on 18 Dec 2023 that address the new corporate income tax law and should be read in conjunction with the legislation. Additional guidance released on 18 Nov 2024 adds four FAQs that address how the law is to be interpreted, focusing on asymmetric foreign currency gains and losses, fiscal transparency, adjustments to financial accounting net income or losses and the taxable distribution method. A public consultation on draft legislation that would grant three proposed refundable tax credits was held in Sept 2025: a substance-based tax credit for regulated insurers, a community development tax credit and a utilities infrastructure tax credit. The credits were summarized in a report issued by the Bermuda Tax Reform Commission, which includes various policy recommendations for reforming the tax system and are designed to be treated as qualified refundable tax credits for purposes of the minimum tax rules. The upper house of parliament approved the Corporate Income Tax Amendment (No. 2) Act 2023 on 10 Dec 2025, which makes technical amendments to the minimum tax rules. There are changes to the calculation of net taxable income and the use of current year losses, the allocation of income/loss in periods where an entity is or is not deemed to be a Bermuda CE, fiscal transparency, foreign currency conversion, etc. The act still must receive the governor’s assent and be published before it becomes effective. Notification/Filing: The Corporate Entities (Miscellaneous) Amendment Act 2024 includes a definition of a CE and requires in-scope entities to declare their Bermuda CE status at the time of registration or incorporation and amends the requirements for annual returns, declarations and compliance certificates to include information on an entity's Bermuda CE status. |
Brazil | Law No. 15,079 of December 27, 2024 | Overview: The law (Law 15.079) introducing an “additional social contribution on net profits” (“additional CSLL”) was signed by the president and published in Brazil’s official gazette on 30 Dec 2024 and is effective as from 1 Jan 2025. The law is based on the QDMTT in the OECD GloBE rules and sets a 15% minimum ETR to ensure minimum global taxation for in-scope MNEs. The additional CSLL applies for fiscal years starting on or after 1 Jan 2025 and operates as a supplement to the Social Contribution on Profits (CSLL) levied on "excess profits," as defined. The law also includes the OECD CbCR temporary safe harbour for fiscal years starting on or before 31 Dec 2026 and ending on or before 30 Jun 2028. The law does not include an IIR or a UTPR but it does require the Brazilian executive branch to submit a legislative proposal to the congress that would revise domestic law to introduce an IIR (but no UTPR). A public consultation document published by the tax authorities on 29 Aug 2025 contains proposed changes to additional CSLL rules. Among the proposed changes are adoption of the OECD administrative guidance published after 2023, allowing Brazilian CEs to track deferred tax liabilities on an aggregated basis for deferred tax liability recapture purposes, revising the rules governing the allocation of cross-border covered taxes and the allocation of cross-border deferred taxes and other clarifications. The consultation ended on 12 Sept; if the proposed rules are adopted, they will apply retroactively as from 1 Jan 2025. Several Normative Instructions (NI) have been issued since the additional CSLL law became effective: - An NI released on 3 Oct 2025 updates the rules to incorporate OECD guidance dating from Jun 2024 and Jan 2025 and clarifies areas, such as entity classification, fiscal year alignment for CEs, etc. These changes generally apply retroactively as from 1 Jan 2025, although some apply as from 1 Jan 2026.
- An NI issued on 24 Mar 2025 clarifies the calculation of the CSLL and amends the penalty rules.
- An NI released on 3 Oct 2024 sets out the mechanisms for calculating GloBE income (or loss), the top-up tax calculation and procedures for implementation of the rules.
Notification/Filing: A Normative Act will set out the filing obligations for the additional CSLL. The legislation does require CEs to collect the top-up tax by the last business day of the seventh month following the end of the fiscal year. BDO Insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/brazil-pillar-two-rules-adopted |
Bulgaria | Law Amending the Corporate Income Tax Act (to implement the EU Minimum Tax Directive) | Overview: The legislation that transposes the EU global minimum taxation directive into Bulgarian law was published in the official gazette on 22 Dec 2023 and generally became effective on 1 Jan 2024. Bulgaria’s legislation includes an IIR and a UTPR, and the country has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Bulgarian resident entities on a consolidated basis. The IIR and QDMTT apply for fiscal years starting on or after 31 Dec 2023 and the UTPR applies for fiscal years starting on or after 31 Dec 2024. Amendments to the Corporate Income Tax Act published on 27 Mar 2025 implement the transitional UPTR safe harbour as provided in the OECD’s July 2023 guidance, introduce rules for the QDMTT during the final tax period of companies in liquidation, insolvency, etc. and explicitly exclude sovereign wealth funds from the definition of a UPE. Bulgaria’s IIR and DMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: There is no registration requirement in Bulgaria, but a notification may need to be filed, as well as the GIR and top-up tax return. Each CE in Bulgaria must file the GIR, although if there are multiple CEs in Bulgaria, a local entity can be designated to submit the report on behalf of the other CE. A GIR is not required to be filed if it is submitted by the UPE or a designated entity in a jurisdiction that has concluded a qualifying automatic exchange of information agreement with Bulgaria for the relevant fiscal year. If the UPE or designated entity files the GIR, the Bulgarian CE or designated local entity must file a "notification of filing entity" in accordance with the procedure approved by the National Revenue Agency. The GIR must be filed electronically within 15 months from the end of the relevant tax period (18 months for the first year). A top-up tax return must be filed and tax paid within 15 months from the end of the relevant fiscal year (18 months for the first year). For tax periods ending before 31 Mar 2025, the deadline is 30 Jun 2026. |
Cabo Verde | | Overview: The 2026 budget submitted to parliament on 1 Oct 2025 contains a proposal to introduce a qualified global minimum tax (known as an “IMG”) at a rate of 15% that would apply to CEs in Cape Verde that are members of an MNE group or large national group with annual revenues equal to or exceeding EUR 750 million in at least two of the preceding four years. If the ETR of a CE is below 15%, a national qualified top-up tax would be payable, equal to the difference between the 15% IMG rate and the lower ETR of the entities based in Cape Verde. Applicable rules and procedures will be set out in separate legislation. If the measures are approved by the National Assembly and the president, they will take effect on 1 Jan 2026. |
Canada | Global Minimum Tax Act | Overview: The Global Minimum Tax Act received royal assent and became law on 20 Jun 2024, implementing the global minimum tax rules into Canadian law. The legislation includes an IIR and domestic minimum top-up tax that is intended to be a QDMTT, which apply to fiscal years of in-scope MNE groups starting on or after 31 Dec 2023. A UTPR was not included in the legislation. A public consultation was held in 2024, which focused on tax proposals in Budget 2024, including draft legislation that would introduce a 15% UTPR on profits of covered MNEs, regardless of where they do business. The UTPR allows countries where an MNE group operates to collect the top-up tax in cases where a parent company's home country does not impose a qualifying IIR. The UTPR still has not been enacted. Canada’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. The legislation incorporate the OECD guidance released since Aug 2023, including the qualified domestic minimum top-up safe harbour and the non-material constituent entities safe harbour. The Department of Finance held a consultation in Aug and Sept 2025 on draft legislation that includes technical changes to the Global Minimum Tax Act. Notification/Filing: There may be a registration requirement (to be announced), and there is a notification requirement. In-scope entities must file a GIR and a top-up return. The Canada Revenue Authority must be notified if a qualifying foreign filing entity will file GIR; the notification may be made by a designated entity on behalf of the MNE group. The GIR must be filed by a Canadian UPE or Canadian designated entity no later than 15 months after the end of the relevant fiscal year (18 months for the first year of application). If an MNE group has multiple Canadian CEs, an entity may be appointed to file the GIR on behalf of all Canadian CEs. A GIR is not required to be filed by a Canadian CE if it is filed by the UPE or designated filing entity in a jurisdiction that has a qualifying competent authority agreement in effect with Canada on or before the GIR exchange date for the relevant fiscal year. Each Canadian entity liable for top-up tax or designated filing entity must file a top-up tax return and pay the top-up tax due no later than 15 months after the end of the relevant fiscal year (18 months for the first year of application). BDO Insights https://www.bdo.ca/insights/2023-federal-budget/international-tax-measures |
Croatia | Minimum Global Corporate Income Tax Act | Overview: The draft legislation that transposes the EU global minimum taxation directive into Croatian law (the Minimum Global Corporate Income Tax Act) was published in the official gazette on 22 Dec 2023 and generally became effective on 1 Jan 2024. The legislation includes an IIR and UTPR, and Croatia has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Croatian resident entities on a consolidated basis. The IIR and QDMTT apply for fiscal years starting on or after 31 Dec 2023 and the UTPR applies for fiscal years starting on or after 31 Dec 2024. Amendments to the Minimum Global Corporate Income Tax Act passed on 5 Dec 2025 include changes to further align Croatian rules with the OECD GloBE Rules and address the procedure for filing a top-up return. The act still must be published before it becomes effective. Croatia’s IIR and DMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: Croatia has a registration requirement but no notification of filing entity requirement. In-scope entities also must file a GIR and a top-up tax return. Legislation passed on 5 Dec 2025 provides that where there are several CEs in Croatia, one of them must file a single tax return for all of the Croatian entities. A notification of the filing entity must be submitted if the GIR is filed by the UPE or designated filing entity in another jurisdiction. The notification must be made within 15 months from the end of the relevant fiscal year (18 months for the first year of application). If an in-scope MNE group has multiple Croatian entities, one entity can be appointed as the designated local entity to submit the notification on behalf of all Croatian CEs. Each Croatian CE must submit a GIR, although a GIR is not required in Croatia if the return is filed by a UPE or designated filing entity in a jurisdiction that has a qualifying competent authority agreement in effect with Croatia for the relevant year. A local entity may be designated as the filing entity if there are multiple CEs in Croatia. The GIR must be filed within 15 months from the end of the relevant fiscal year (18 months for the first year of application). The GIR contains information about the group entities, group structure, ETR, top-up tax allocation and attribution, and other information needed to calculate the top-up tax. The Ministry of Finance will be releasing a form for submission of the GIR. The top-up tax return must be filed within 30 days after the deadline for filing of the GIR. |
Curacao | Minimum Tax Ordinance | Overview: The ordinance that implements the global minimum tax in Curacao, as well as an accompanying explanatory memorandum, were published on 27 Dec 2024. The rules generally follow the GloBE rules and certain parts of the OECD administrative guidance. The law includes an IIR and DMTT, which apply to fiscal years starting on or after 1 Jan 2025 but no UTPR. Notification/Filing: There is a notification requirement, and in-scope entities must file a GIR and a top-up tax return. CEs in Curaçao must notify the tax authorities of the identity of the entity (i.e., the UPE or a designated filing entity) is filing the GIR and in which jurisdiction. It is unclear when the notification is due, but apparently by the deadline for filing the return. A GIR must be filed within 15 months after the end of the fiscal year (18 months for the first year). The top-up tax return must be filed within 17 months after the end of the fiscal year (20 months for the first year), with tax due paid at that time |
Cyprus | Law on Ensuring a Global Minimum Level of Taxation of Multinational Enterprise Groups and Large Domestic Groups in the European Union | Overview: Legislation that implements the EU global minimum taxation directive into Cyprus law was approved on 12 Dec 2024 and was published in the government gazette on 18 Dec. The legislation follows the EU directive and includes provisions from the OECD administrative guidance. The legislation includes an IIR and UTPR, and Cyprus has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Cypriot resident entities on a consolidated basis. The IIR and QDMTT apply for fiscal years starting on or after 31 Dec 2023 and the UTPR applies for fiscal years starting on or after 31 Dec 2024. The government formally consented to the safe harbours and the OECD administrative guidance on 24 Jul 2024.
Notification/Filing: Cyprus has notification requirements and in-scope entities must file a GIR and a top-up tax return. Each CE in Cyprus must notify the Commissioner of Taxation that it falls within the scope of the global minimum tax rules within 15 months of the last day of the relevant fiscal year (18 months for the first year). A notification of the filing entity must be submitted if the GIR is not filed locally within the same time frame. Each CE in Cyprus must file a GIR, although if there are multiple CEs in Cyprus, an entity may be designated to file the return on behalf of all CEs. A GIR need not be filed in Cyprus if it is filed by the UPE or designated filing entity located in a jurisdiction that has a qualifying competent authority agreement in effect with Cyprus for the relevant year. An in-scope Cypriot CE must file a top-up tax self-assessment return and pay the tax due within 30 days of the deadline for filing the GIR. Other: On 11 Dec 2025, the European Commission announced that it has closed the infringement proceedings against Cyprus for failure to notify the Commission about measures transposing the EU global minimum taxation directive into its domestic law by the 31 Dec 2023 deadline. Infringement proceedings had been initiated against nine member states. |
Czech Republic | Law on top-up taxes for large multinational groups and large domestic groups | Overview: The bill transposing the EU global minimum tax directive into Czech law, the Law on Top-up Taxes for Large Multinational Groups and Large Domestic Groups, was published in the official gazette on 29 Dec 2023 and generally became effective on 1 Jan 2024. The legislation includes an IIR and a UTPR, and the Czech Republic has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Czech resident entities on a consolidated basis. The IIR and QDMTT apply for fiscal years starting on or after 31 Dec 2023 and the UTPR applies for fiscal years starting on or after 31 Dec 2024. The Czech Republic has adopted the OECD administrative guidance. The Czech Republic’s IIR and DMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: There is no registration requirement in the Czech Republic but a notification may need to be submitted. In-scope entities must file a GIR and a top-up tax return. A notification of the filing entity must be submitted if the GIR is filed by the UPE or designated filing entity in a jurisdiction that has an international exchange agreement in effect with the Czech Republic for the relevant year. Each in-scope Czech CE must file a GIR, although if the MNE group has multiple Czech CEs, one entity can be appointed to file the GIR on behalf of all Czech CEs. However, it is not necessary to file a GIR if one has been filed by the UPE or designated filing entity located in a jurisdiction that has concluded an international exchange of information agreement in effect with the Czech Republic for the relevant year. The GIR must be filed within 15 months (originally 10 months) from the end of the relevant fiscal (18 months for the first year). An in-scope Czech CE is required to file a top-up tax return and pay the tax due within 22 months (originally 10 months) from the end of the relevant fiscal year. Other: On 17 Dec 2025, the Czech Republic withdrew its opposition to the proposed side-by-side system that would exempt US companies from the Pillar Two rules following meetings with US representatives. Estonia and Poland also have agreed to accept the rules. |
Denmark | | Overview: The bill transposing the EU global minimum taxation directive into Danish law was published in the official gazette on 13 Dec 2023 and generally became effective as from 31 Dec. The legislation includes an IIR and a UTPR, and Denmark has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Danish resident entities on a consolidated basis. The IIR applies to fiscal years starting on or after 31 Dec 2023 and the UTPR applies to fiscal years starting on or after 31 Dec 2024 (but the UTPR applies as from 31 Dec 2023 for a low-tax CE that is resident in a country that has elected to not to apply the IIR and the UTPR for six consecutive fiscal years beginning from 31 Dec 2023). Denmark’s IIR and DMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Denmark has incorporated the following safe harbours: Transitional CbCR safe harbour, QDMTT safe harbour, transitional UTPR safe harbour, NMCE simplified calculations safe harbour. Legislation that applies as from 1 Jul 2024 incorporates the 2023 OECD administrative guidelines on the global minimum taxation rules into the Danish Minimum Taxation Act. Parliament passed a subsequent bill on 3 Jun 2025 that incorporates the OECD's administrative guidelines from Jun 2024 and Jan 2025 into the domestic law. These measures apply retroactively for fiscal years starting on or after 31 Dec 2023. The consolidated text of the Minimum Taxation Act, as amended by Act No. 750/2025, which entered into force on 1 July 2025. The Act aligns with the latest OECD administrative guidance and clarifies the interaction between international joint taxation and the minimum tax regime, as well as the treatment of deferred taxes. Notification/Filing: There are registration and notification requirements in Denmark and in-scope entities must file a GIR and a top-up tax return. CEs operating in Denmark are required to fill in two additional fields on their corporate tax return (originally the 2024 return but this rule may apply going forward) that relate to whether the CE is part of a group with revenue exceeding EUR 750 million in the previous four years and whether the entity was subject to the Minimum Taxation Act. All in-scope Danish CEs must notify the Customs and Tax Administration of this fact within six months of the end of the reporting year and report. Any changes must be reported within 30 days. A notification of the filing entity must be submitted if the GIR is filed by the UPE or designated filing entity in a jurisdiction that has an information exchange agreement in effect with Denmark for the relevant year. Each in-scope Danish CE must file a GIR, although if the MNE group has multiple Danish CEs, one entity can be appointed to file the GIR on behalf of all Danish CEs. However, it is not necessary to file a GIR if one has been filed by the UPE or designated filing entity located in a jurisdiction that has concluded a qualified competent authority agreement in effect with Denmark for the relevant year. The GIR must be filed within 15 months from the end of the relevant fiscal (18 months for the first year). A Danish CE entity is responsible for filing a top-up tax return and paying the top-up tax within 17 months after the last day of the reporting year (20 months for the first year). |
Estonia | Income Tax Act Sections 5410-5411 | Overview: A law published on 2 May 2024 transposed the EU global minimum taxation directive into Estonian law. The law is effective as from 12 May 2024. Estonia has elected to delay application of the IIR, UTPR and QDMTT until 2030 and has notified the European Commission that it intends to postpone the application of the IIR and UTPR for six consecutive fiscal years as provided in article 50(1) of the directive. Article 50(1) allows EU member states with 12 or fewer UPEs of in-scope MNEs to delay the application of the rules. However, a member state that opts to make the election still must transpose all the other relevant directive measures to enable taxpayers and other EU member states and third countries to properly apply the system. Five member states—Estonia, Latvia, Lithuania, Malta and Slovakia—have exercised the election to defer application of the IIR and UTPR. In a press release dated 13 Nov 2025, following a meeting with EU finance ministers, the Estonian Minister of Finance called for flexibility in implementing the global minimum tax and suggested that EU member states that have elected to postpone implementation have the right to decide on implementation beyond 2030. Notification/Filing: Even though Estonia is deferring implementation of Pillar Two and compliance obligations will not arise until 2030, preparation is needed. Registration and notification are not addressed in the relevant legislation, nor is the GIR. Although Estonia’s legislation does not require an Estonian CE to submit a GIR, the CE must ensure that sufficient data is provided to fulfill the obligations of CEs in other EU member states. Other: On 17 Dec 2025, Estonia withdrew its opposition to the proposed side-by-side system that would exempt US companies from the Pillar Two rules following meetings with US representatives. The Czech Republic and Poland also have agreed to accept the rules. On 12 Dec 2025, Estonia, Latvia, Lithuania, Malta and the Slovak Republic submitted a joint statement to the EU Finance Ministers requesting a review of the EU's implementation of the Pillar Two global minimum tax rules and specifically asked that the option to postpone application of the minimum tax be extended for an additional six years. On 10 Dec 2025, Estonia formally objected to the proposed exemption for US companies (i.e., the side-by-side system) from the 15% global minimum tax provisions and on 3 Dec requested that the European Commission suspend the Pillar Two directive, repeal it or amend article 50 to provide a permanent derogation for countries with only a few UPEs. On 11 Dec 2025, the European Commission announced that it has closed the infringement proceedings against Estonia for failure to notify the Commission about measures transposing the EU global minimum taxation directive into its domestic law by the 31 Dec 2023 deadline. Infringement proceedings had been initiated against nine member states. BDO Insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/european-union-five-eu-member-states-elect-to-delay-application-of-iir-and-utpr https://www.bdo.global/en-gb/microsites/tax-newsletters/corporate-tax-news/issue-62-may-2022/estonia-agreement-reached-to-postpone-estonia%E2%80%99s-implementation-of-the-global-minimum-tax |
Finland | Act on minimum tax for large corporations | Overview: The bill transposing the EU global minimum taxation directive into Finnish law, the Act on a Minimum Tax for Large Corporate Groups, was published in the official gazette on 28 Dec 2023 and became effective on 1 Jan 2024. The legislation includes an IIR and UTPR, and Finland has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Finnish resident entities on a consolidated basis. The IIR and QDMTT apply for fiscal years starting on or after 31 Dec 2023 and the UTPR applies for fiscal years starting on or after 31 Dec 2024. Changes to the minimum tax law adopted on 19 Dec 2024 incorporate the 2023 OECD administrative guidance, adopt the CbCR safe harbour, simplify the method for calculating the minimum tax and address the treatment of tax credits, etc. In Mar 2025, the tax authorities released guidance on the general principles and goals of the Pillar Two rules and the types of taxes that must be taken into account when calculating the ETR. Guidance released on 25 Nov 2025 explains how to allocate profits and losses and related taxes between MNE group entities, in particular, with respect to PEs, CFCs and hybrid entities. A consultation held 6-19 Nov 2025 sought feedback on proposed amendments to incorporate OECD guidance issued in Jun 2024 and Jan 2025 and introduce a new anti-avoidance provision. The latter provision would allow the Finnish tax authorities to disallow arrangements designed to avoid the minimum tax but also would allow the authorities to issue advance rulings on minimum tax liabilities. Once enacted, the changes will become effective in 2026 and generally will apply to fiscal years starting on or after 1 Jan 2024. Finland’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: There is no registration requirement in Finland, but a notification may be required. In-scope entities must file a GIR and a top-up tax return. If an in-scope MNE group files a GIR in a jurisdiction other than Finland, a Finnish CE must notify the Finnish tax authorities about the filing entity's details within 15 months of the CE's fiscal year end (18 months for the first fiscal year the rules apply). A GIR must be filed electronically within 15 months of the CE’s fiscal year-end (18 months for the first fiscal year). If the MNE group has multiple CEs in Finland, a local entity can be appointed to submit the return on behalf of the other CEs. A GIR is not required in Finland if it is filed by the UPE or designated reporting entity in a jurisdiction that has concluded a qualifying competent authority agreement with Finland for the relevant year. A top-up tax return must be filed electronically within 15 months of the CE’s fiscal year-end (18 months for the first fiscal year). It is unclear when payment of the tax is due. |
France | Article 33 of Finance Law for 2024 (Law No. 2023-1322 of 29 December 2023) (the rules have been implemented in the General Tax Code, articles 223, et seq | Overview: Finance Law 2024, which transposes the EU global minimum taxation directive into French law, was published in the official gazette on 30 Dec 2023 and entered into effect on 1 Jan 2024. The legislation includes an IIR and a UTPR, and France has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on French resident entities on a consolidated basis. The IIR and QDMTT apply for fiscal years starting after 31 Dec 2023 and the UTPR applies for fiscal years starting after 31 Dec 2024. The Finance Bill for 2025 contained measures that incorporate the OECD administrative guidance into the French Pillar Two legislation. The 2026 Finance Bill released on 14 Oct 2025 includes changes to the domestic Pillar Two rules, including a new definition of a UPE and changes to the tax recapture rules, as well as measures that would incorporate the Jun 2024 OECD administrative guidance and DAC 9. However, on 21 Nov, parliament rejected part of the bill. The tax authorities published guidance on the Pillar Two rules on 3 Dec 2025 that clarifies the transition rules that apply when an MNE group becomes subject to the rules. France’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: France requires all CEs located in the country that are members of an in-scope MNE group or large national group to notify the tax authorities that they are group members. There is no requirement to notify the authorities of the filing entity. In-scope entities also must submit a GIR and a statement of payment of the top-up tax. A decree published in the official gazette of 5 Dec 2024 introduced the filing obligations for MNE groups subject to the GloBE rules and provided for the exchange of GIR with other jurisdictions. On 24 Jan 2025, the French tax authorities released the annual form for in-scope entities to use to comply with the reporting requirements. French CEs of an in-scope MNE group must indicate in their annual corporate income tax return that they belong to the group, the identity of the UPE or designated filing entity, the jurisdiction of the UPE or designated filing entity. A GIR must be filed electronically within 15 months of the fiscal year-end (18 months for the first fiscal year). If the MNE group has multiple CEs in France, a local entity can be appointed to submit the return on behalf of the other CEs. A GIR is not required in France if it is filed by the UPE or designated reporting entity in a jurisdiction that has concluded a qualifying competent authority agreement with France for the relevant year. In addition to the GIR, each French CE must file a statement of payment of the top-up tax in France. The statement has to include general information on the filing entity and the amount of top-up tax due. A notice published on 12 Sept 2025 reminds in-scope entities to complete section II of the 2065-INT-SD notification form by the deadline for filing the income statement. The tax authorities updated the general Pillar Two guidance on 9 Dec 2025 to release a user guide for filing the GIR return. |
Germany | Law implementing Council Directive (EU) 2022/2523 on ensuring a global minimum tax and other accompanying measures | Overview: The legislation that transposes the EU minimum tax directive into German law was published in the official gazette on 27 Dec 2023. The legislation includes an IIR and a UTPR, and Germany has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on German resident entities on a consolidated basis. The IIR and QDMTT apply for fiscal years starting after 31 Dec 2023 and the UTPR applies for fiscal years starting after 31 Dec 2024. The lower house of parliament approved changes to Germany’s Pillar Two legislation on 13 Nov 2025 but the draft still has to be approved by the federal council. The Minimum Tax Adjustment Act would incorporate the latest OECD administrative guidelines for the GloBE rules into German law, in particular, the guidelines from Dec 2023, Jun 2024 and Jan 2025, eliminate some administrative burdens and implement DAC9 on the exchange of GIRs. Germany’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: Germany has a registration requirement but no notification of filing entity requirement. In-scope entities also must file a GIR and a top-up tax return. The group head (i.e., the German UPE, German parent of all German CEs, a German designated CE or, if no entity is designated, the most economically significant German CE) of the German minimum tax group must be determined by the end of the taxable period for which the tax liability arose and it must notify the tax authorities of its status as such within two months after the end of that taxable period using an official form. The first notification deadline was 28 Feb 2025 for calendar year MNE groups (28 Feb 2026 for groups using a different fiscal year). On 5 Aug 2025, the Ministry of Finance announced the officially prescribed data set and the data set description for the submission of the GIR. The official group parent notification form was first released on 17 Oct 2024 and updated on 11 Mar 2025. A consultation was held 29 Sept-6 Oct 2025 on compliance rules for the exchange of the GIR, simplified reporting and the completion of the GIR to reflect the OECD guidance. Each German CE must submit a GIR, although a GIR is not required in Germany if the return is filed by a UPE or designated filing entity in a jurisdiction that has a qualifying competent authority agreement in effect with Germany for the relevant year. The GIR must be filed within 15 months from the end of the relevant fiscal year (18 months for the first year of application). The GIR contains information about the group entities, group structure, ETR, top-up tax allocation and attribution, and other information needed to calculate the top-up tax. A local entity may be designated as the filing entity if there are multiple CEs in Germany. A consultation was held 29 Sept-6 Oct 2025 on compliance rules for the exchange of the GIR, simplified reporting and the completion of the GIR to reflect the OECD guidance. The group head must file an annual self-assessment return and pay the top-up tax on behalf of the German minimum tax group within 15 months from the end of the relevant fiscal year (18 months for the first year of application). Top-up tax must be paid within one month following the filing of the return. BDO insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/germany-impending-deadline-to-submit-notification-as-head-of-a-tax-group-for-pillar-two-purposes |
Gibraltar | Global Minimum Tax Act 2024 | Overview: The bill that sets out the Global Minimum Tax Act 2024 was approved by parliament and enacted on 23 Dec 2024. The legislation contains an IIR that applies for fiscal years starting on or after 31 Dec 2024 and a domestic top-up tax (DTT) that applies for fiscal years starting on or after 31 Dec 2023. There is no UTPR and it is unclear whether Gibraltar will introduce a UTPR. Gibraltar’s IIR and DTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Rules that apply as from 20 Feb 2025 allow a Gibraltar parent entity that falls under the Income Tax Act 2010 and the Global Minimum Tax Act 2024 to elect to be taxed only under the latter. The election must be approved by the tax authorities. Notification/Filing: The Gibraltar tax authorities are working on guidance relating to registration, notification and return filing. Guidance notes released in early Dec 2025 set out the rules for registration and notification in Gibraltar and clarify the return filing process. A UPE or designated filing entity must file a GIR on behalf of the MNE group unless a GIR is filed by a UPE or designated filing entity in a jurisdiction that has concluded a qualifying competent authority agreement with Gibraltar, in which case an annual notification must be filed in Gibraltar within three months of the due date for filing the GIR. Otherwise, the GIR must be filed within 15 months after the end of the relevant fiscal year (18 months for the first year of application). Where a GIR is filed outside Gibraltar, an in-scope MNE group must file a specific form with the Gibraltar tax authorities (Form GMTA1) by the same deadline. The top-up tax return must be filed within 15 months after the end of the relevant fiscal year (18 months for the first year). The domestic top-up tax must be paid before the GIR filing deadline. |
Greece | Law 5100/2024 (in Greek only) | Overview: The legislation implementing the EU global minimum tax directive (Law 5100/2024) into Greek law was published in the official gazette on 5 Apr 2024. The legislation is almost identical to that in the EU directive. The legislation includes an IIR and a UTPR and Greece has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Greek resident entities on a consolidated basis. The IIR and QDMTT apply for fiscal years starting on or after 31 Dec 2023 and the UTPR applies for fiscal years starting on or after 31 Dec 2024. The legislation contains three safe harbour rules: a CbCR transitional safe harbour, a UTPR transitional safe harbour and a permanent QDMTT safe harbour. Greece’s IIR and DTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: There is no registration requirement in Greece, but a notification must be submitted, as well as a GIR and top-up tax return. The Greek tax authorities must be notified about the entity that will be responsible for filing the information and top-up tax returns within 15 months after the last day of the reporting fiscal year (18 months for the first fiscal year of application). Each CE in Greece must file a GIR, although if the MNE group has multiple CEs in Greece, a local entity can be appointed to file the GIR on behalf of the other CEs. A GIR is not required to be filed in Greece if it is filed by the UPE or designated filing entity located in a jurisdiction that has concluded a qualifying competent authority agreement with Greece for the relevant year. The GIR must be filed within 15 months from the end of the relevant fiscal year (18 months for the first year of application). The top-up tax return must be filed within 17 months after the last day of the reporting fiscal year (20 months for the first fiscal year of application). Tax due must be paid by the last business day of the month following the submission of the computation data. Other: On 11 Dec 2025, the European Commission announced that it has closed the infringement proceedings against Greece for failure to notify the Commission about measures transposing the EU global minimum taxation directive into its domestic law by the 31 Dec 2023 deadline. Infringement proceedings had been initiated against nine member states. |
Guernsey | Income Tax (Approved International Agreements) (Implementation) (OECD Pillar Two GloBE Model Rules) Regulations, 2024 | Overview: On 26 Nov 2024, Guernsey introduced the Income Tax (Approved International Agreements) (Implementation) (OECD Pillar Two GloBE Model Rules) Regulations, 2024, which gives effect to the OECD GloBE rules. The regulations include an IIR (called a “multinational top-up tax”) that imposes tax on a parent entity with a foreign subsidiary with low-taxed income and a QDMTT that sets a 15% ETR for in-scope Guernsey entities that are not already taxed at a 15% or more ETR. Guernsey is not adopting a UTPR at this time. The IIR and QDMTT apply for fiscal years starting on or after 1 Jan 2025. The regulations incorporate the 2023 and 2024 OECD administrative guidance. Guernsey’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: There is a registration requirement in Guernsey and in-scope entities must file a GIR and top-up tax return. The portal for submitting the registration and top-up tax return is under development and expected to be operational by 2026. A qualifying MNE must appoint a Guernsey entity in the group as the domestic filing entity that will be responsible for registering all entities in the group and submitting the IIR and QDMTT returns. The deadline for appointment and registration is 28 Feb 2026 (extended from the original date of 31 Dec 2025) for calendar year MNE groups. In Nov 2025, the government issued a “registration guide” for the Pillar Two taxes to help in-scope MNE groups complete the registration form. The government previously issued guidance on the Pillar Two legislation, which includes information on the registration process and deadlines, and includes an FAQ. In addition to registration, IIR and QDMTT returns and a GIR must be filed within 15 months after the end of the fiscal year (18 months for the first year). |
Hong Kong | Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024) | Overview: On 6 Jun 2025, Hong Kong enacted the bill that implements the Pillar Two rules (Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024). The legislation introduces an IIR and a domestic minimum top-up tax (the latter known as HKMTT) that apply for fiscal years starting on or after 1 Jan 2025. A UTPR will be introduced later. The HKMTT grants the Hong Kong Special Administrative Region first priority in collecting top-up tax from entities of in-scope MNE groups whose ETR in Hong Kong is below 15% and to increase it to 15%; otherwise, the relevant top-up tax may be collected by other jurisdictions in which the group operates (provided those jurisdictions have signed onto the BEPS 2.0 initiative). The legislation also includes safe harbours and other measures, such as a shorter recordkeeping requirement, an extended time limit for filing the GIR in certain circumstances and allowing the HKMTT to be credited against profits tax in certain circumstances. Changed from the original version of the bill, Hong Kong is adopting the sole or dominant purpose test instead of the main purpose test as a GAAR. Notification/Filing: Hong Kong has a registration and notification of filing entity requirement, and in-scope entities must submit a top-up tax return. Each Hong Kong CE must submit an annual top-up tax notification that includes information on the Hong Kong CEs, the UPE, if outside Hong Kong and any designated filing entity. If the MNE group has multiple CEs in Hong Kong, a local entity can be designated annually as the entity responsible for filing the notification on behalf of the other Hong Kong CEs. This notification must be made within six months of the end of the relevant fiscal year. The Hong Kong CE must submit a notification of filing entity if the GIR is not filed locally, also within six months of the end of the relevant fiscal year. Each Hong Kong CE is required to furnish a single top-up tax return for the purposes of the GloBE rules and HKMTT (top-up tax return) in a prescribed manner and form no later than 15 months after the last day of the reporting fiscal year (18 months for the first year of application). The top-up tax return includes information required in the standard GIR. The GIR information will not be required to be filed in Hong Kong if that information is filed in a jurisdiction that has concluded a qualifying competent authority agreement with Hong Kong for the relevant year. Hong Kong CEs may designate one Hong Kong CE to file the top-up tax return to the IRD, relieving all other Hong Kong CEs of the group from their filing obligation. The designated local entity has to be appointed annually. The IRD published updated guidance on the minimum tax rules on 17 Oct 2025 that contains examples of the electronic filing of tax returns. The Inland Revenue Department (IRD) is issuing letters to MNE groups to identify in-scope MNE groups with operations in Hong Kong and alert them to compliance deadlines. The letter also provides an overview of the Pillar Two taxes and outlines the support offered by the IRD. The IRD is developing a portal for registration and submission of the returns. BDO insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/hong-kong-tax-authorities-issue-pillar-two-compliance-letters-to-mne-groups https://www.bdo.com.hk/getattachment/f24981bb-1822-4bf7-9589-e566856d88da/Hong-Kong-Tax-Jan-2025-issue-(Final).pdf?lang=zh-CN https://www.bdo.global/en-gb/microsites/tax-newsletters/global-tax-alerts/hong-kong-implementation-of-pillar-two-minimum-tax-deferred-to-2025 https://www.bdo.global/en-gb/microsites/tax-newsletters/global-tax-alerts/hong-kong-2022-23-budget-includes-measures-to-implement-beps-2-0
|
Hungary | Act LXXXIV of 2023 on “Additional taxes ensuring a global minimum tax level and amending certain tax laws in this context” | Overview: The legislation that transposes the EU global minimum taxation directive into Hungarian law was published in the official gazette on 30 Nov 2023 and is generally effective as from 31 Dec 2023. The legislation includes an IIR and UTPR, and Hungary has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Hungarian resident entities on a consolidated basis. The IIR and QDMTT apply for fiscal years starting on or after 31 Dec 2023 and the UTPR applies for fiscal years starting on or after 31 Dec 2024. The autumn tax package released on 2 Oct 2025 includes proposed changes to the operation of the transitional CbCR safe harbour. A decree released by the Ministry for National Economy on 14 Nov 2025 contains implementing rules for the application of tax exemptions (i.e., the transitional CbCR safe harbour, the QDMTT safe harbour, the simplified calculations safe harbour and the UTPR safe harbour) in Hungary’s global minimum tax rules. The decree will become effective 31 days after publication. Hungary’s IIR and DMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: Hungary has a registration and notification of filing entity requirement and in-scope entities are required to file a GIR and a top-up tax return. Each Hungarian in-scope CE (or designated local entity) must register annually with the National Tax and Customs Administration within 12 months from the start of the relevant fiscal year. If an in-scope MNE group files a GIR in a jurisdiction other than Hungary, a Hungarian CE must notify the tax authorities about the filing entity's details within six months after the GIR is filed. Each Hungarian CE is required to file the GIR, although a local entity may be designated to file on behalf of all the Hungarian CEs. A GIR is not required to be filed in Hungary if it is filed by the UPE or designated filing entity located in a jurisdiction that has concluded a qualifying competent authority agreement with Hungary for the relevant year. The GIR must be filed within 15 months from the end of the relevant fiscal year (18 months for the first year of application). A local CE must submit a top-up tax information return for the declaration and data reporting related to the top-up tax. A Hungarian CE or designated local entity subject to the DMTT must file a return and pay any remaining tax within 15 months from the end of the relevant fiscal year (18 months for the first year of application). An advance payment of tax must be made by the 20th day of the 11th month following the last day of the relevant fiscal year. The final version of the QDMTT advance return and filing instructions were published by the National Tax and Customs Administration on 15 Oct 2025. BDO Insights https://www.bdo.global/en-gb/microsites/tax-newsletters/corporate-tax-news/issue-59-july-2021/hungary-hungary-declines-to-endorse-plan-for-global-minimum-tax |
Iceland | | Overview: The 2026 budget presented on 8 Sept 2025 includes the introduction of the 15% global minimum tax based on the EU directive and the OECD model rules. The proposals include an IIR and a QDMTT that would apply to entities that are part of a consolidated group with annual revenue of EUR 750 million or more in at least two of the four immediately preceding financial years. If enacted, the IIR and QDMTT would apply for fiscal years starting on or after 31 Dec 2025. Consultations have been held on the proposed rules. |
India | | Overview: India is preparing for the enactment of Pillar Two legislation by setting up a panel to frame appropriate rules. On 19 Aug 2025, revised accounting standards were published to bring the rules in line with IAS 12 and introduce disclosure requirements related to the planned global minimum tax. The Finance Act 2025 does not include a roadmap or details on the introduction of Pillar Two, but the finance minister mentioned that abolition of the Equalization Levy is a step in the direction of the implementation of the Two Pillar framework. |
Indonesia | Regulation No. 136 of 2024 (in Indonesian only) | Overview: In a press release issued on 16 Jan 2025, the Ministry of Finance announced the issuance of a regulation implementing the global minimum tax rules. Regulation No. 136 of 2024 was issued on 31 Dec 2024 and became effective on 1 Jan 2025. The regulation includes an IIR, a UTPR and a QMDTT. The IIR and QDMTT apply for fiscal years starting on or after 1 Jan 2025, with the UTPR applying a year later, i.e., for fiscal years starting on or after 1 Jan 2026. Further, the regulation introduces several safe harbors. Indonesia’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: The regulation sets out the following filing obligations: (i) a notification; (ii) the GIR; (iii) a UTPR return; and (iv) a DMTT return, all of which must be submitted to the Indonesia Directorate General of Taxes within 15 months after the end of the UPE’s fiscal year (18 months for the first fiscal year). CEs in Indonesia that belong to covered MNE groups must submit a notification that contains specific information to the Indonesian tax authorities. Information to be reported includes details on the UPE and Indonesian CEs, as well as the identity of the designated filing CE if one has been appointed. An Indonesian UPE of a covered group is required to file a GIR that contains information on the identity of the CEs, including their TINS, the jurisdiction where the CE is located and the CE’s status under the GloBE rules, the group structure, calculation of the ETR for each jurisdiction, etc. If the UPE is not an Indonesian company, a CE in Indonesia must submit the GIR if the group designates the CE as the reporting CE or the CE is resident in a jurisdiction that does not have a qualifying competent authority agreement with Indonesia. BDO Insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/indonesia-global-minimum-tax-under-pillar-two-implemented |
Ireland | Section 94 of Finance (No. 2) Act 2023 inserts new Part 4A into the Taxes Consolidation Act 1997 | Overview: Finance (No. 2) Bill 2023 signed by the president on 18 Dec 2023 contains the legislation that transposes the EU global minimum taxation directive into Irish law. The legislation includes an IIR and UTPR, and Ireland has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum effective tax rate on Irish resident entities on a consolidated basis. The IIR and QDMTT apply for fiscal years starting on or after 31 Dec 2023 and the UTPR applies for fiscal years starting on or after 31 Dec 2024. Ireland’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. The 2025 Finance Bill released on 16 Oct 2025 would incorporate the Jan 2025 OECD administrative guidance into Ireland’s Pillar Two rules and implement the DAC9 directive (DAC9 contains rules to facilitate the exchange of information relating to top-up tax returns). The Irish tax authorities have issued the following guidance on the rules: - An e-brief published on 31 Jul 2025 provides clarifications relating to the operation of various Pillar Two rules.)
- An e-brief published on 8 May 2025 updates the Tax and Duty Manual - Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union - Administration to confirm that an exemption applies for a securitization vehicle in respect of the UTPR and QDTT group recovery.)
- An e-brief published on 17 Feb 2025 clarifies the rules relating to the calculation of deferred tax assets as set out in the above Tax and Duty Manual. The manual includes detailed guidance on various administrative requirements under the minimum tax, such as registration procedures, the IIR, UTPR and QDMTT returns, tax payments, compliance and enforcement, etc.)
- An e-brief published on 17 Dec 2024 reflects changes to the manual made by Finance Act 2024 to incorporate parts of the OECD's administrative guidance, including an amended definition of a hybrid entity and clarification of the definition of the owner of a flow-through entity and amended rules on tax. Also on 17 Dec 2024, the tax authorities released an updated Tax and Duty Manual – Outbound Payments Defensive Measures, which confirms that a top-up tax under the Pillar Two rules is not subject to withholding tax under EU defensive measures for outbound payments.
- An e-brief released on 15 May 2024 clarifies the IIR, UTPR and QDMTT and provides more details on the substance-based income inclusion and safe harbours.
- An e-brief released on 8 Aug 2024 announced the release of a new version of the manual.
Notification/Filing: Ireland has a registration requirement and a notification of filing entity requirement. In-scope entities also must file a GIR and a top-up tax return. In-scope Irish entities must register with the Irish tax authorities in respect of each applicable tax within 12 months of the end of the first fiscal year the entity is subject to that tax and provide the following information: - Entity’s name and Irish tax registration number
- Name, location and tax registration number of the entity’s UPE and any designated filing entity
- Details of group filing elections under the UTPR or QDTT
- Other information requested by the Irish tax authorities.
Any change in the information must be reported within 12 months of the end of the fiscal year in which the change takes place. A notification of the filing entity must be submitted if the GIR is filed by the UPE or designated filing entity in another jurisdiction that has an information exchange agreement in effect with Ireland for the relevant year. The notification must be made within 15 months from the end of the relevant fiscal year (18 months for the first year of application). If an in-scope MNE group has multiple Irish entities, one entity can be appointed as the designated local entity to submit the notification on behalf of all Irish CEs. Each Irish CE must submit a GIR, although a GIR is not required in Ireland if the return is filed by a UPE or designated filing entity in a jurisdiction that has a qualifying competent authority agreement in effect with Ireland for the relevant year. A local entity may be designated as the filing entity if there are multiple CEs in Ireland. The GIR must be filed within 15 months from the end of the relevant fiscal year (18 months for the first year of application). The GIR contains information about the group entities, group structure, ETR, top-up tax allocation and attribution, and other information needed to calculate the top-up tax. - Irish CEs that are subject to the IIR, UTPR or QDMTT must submit a top-up tax return within 15 months from the end of the relevant fiscal year (18 months for the first year of application). A local entity may be designated as the filing entity if there are multiple CEs in Ireland.
- The Irish tax authorities launched their Pillar Two hub and registration portal on 14 Aug 2025. The portal also contains information on the Pillar Two rules.
|
Isle of Man | Global Minimum Tax (Pillar Two) Order 2024 | Overview: The Global Minimum Tax (Pillar Two) Order 2024 was approved by the Tynwald on 21 Nov 2024 and became effective on 1 Jan 2025. The order includes a multinational top-up tax (MTUT) and a domestic top-up tax (DMTT), but no UTPR. Both taxes aim to ensure that covered MNEs pay at least a 15% tax on their profits generated within the Isle of Man and profits generated outside the Isle of Man, respectively. The rules apply to fiscal years starting on or after 1 Jan 2025. A notice released on 21 Aug 2025 acknowledges the OECD’s updating of its Central Record of Legislation with Transitional Qualified Status confirming that the IOM’s MTUT is a qualified IIR and the DMTT is a qualified domestic minimum top-up tax with safe harbour status. The Isle of Man’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing Isle of Man has a registration requirement, and in-scope entities are required to file a GIR and a top-up tax return. Guidance published on 24 Apr 2025 addresses how covered MNE groups should use the Pillar Two Online Service for compliance purposes, including registration, group maintenance and accessing and using the document library. The guidance also provides details on appointment of the filing entity and the submission of returns and notifications. In-scope MNE groups are required to appoint a domestic filing entity, i.e., the group member that will be responsible for registration of all group members and for submitting the relevant tax returns. The deadline for registration and the appointment of a domestic filing entity generally will be no earlier than 31 Dec 2025. The GIR must be submitted to the Assessor in such form as may be approved by the Assessor. However, a GIR is not required to be filed if one has been submitted for the relevant fiscal year to another jurisdiction that has a qualifying competent authority agreement in force for that period Covered MNE groups that are within scope of the domestic top-up tax must notify the Assessor and pay any estimated domestic top-up tax liabilities in respect of an entity located in the Isle of Man that intends to enter liquidation, dissolution or any other form of winding up, or otherwise cease to be located in the Isle of Man for domestic top-up tax purposes. The GIR and top-up tax returns must be filed within 15 months after the end of the relevant fiscal year (18 months in the first year). An order dated 21 Jan 2025 that applies retroactively as from 1 Jan provides that a 5% interest rate per annum will apply where the top-up tax is not paid in a timely manner. Other: The governments of Guernsey, Jersey and the Isle of Man announced on 19 May 2023 that they had jointly agreed to adopt the Pillar Two framework and that they would adopt the IIR and a DMTT to provide for a 15% effective tax rate for large in-scope MNEs. In May 2024, the three islands announced a timeline to begin the relevant legislative procedures. BDO Insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/international-corporate-tax-bytes |
Israel | | Overview: On 5 Oct 2025, the Minister of Finance and the tax authorities published comprehensive draft legislation for a DMTT that is intended to be in line with the OECD GloBE rules. The regime would apply to the income of Israeli resident entities that are part of an MNE group with global group turnover of EUR 750 million or more. There are no plans to adopt an IIR or a UTPR at this time. The draft legislation incorporates the OECD's GloBE model rules, commentary and administrative guidance and Israel intends to introduce a qualified refundable tax credit to complement the QDMTT. If enacted, the legislation will apply as from 1 Jan 2026. |
Italy | Decree No. 209 of December 27, 2023 | Overview: The decree that implements the EU global minimum taxation directive into Italian law was published in the official gazette on 28 Dec 2023 and applies as from 1 Jan 2024. The decree includes an IIR and a UTPR, and Italy has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Italian resident entities on a consolidated basis. The IIR and QDMTT apply for fiscal years starting on or after 31 Dec 2023 and the UTPR applies for fiscal years starting on or after 31 Dec 2024. Italy’s IIR and DMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. The authorities have published several sets of guidance on the top-up tax: Guidance published on 17 Feb 2025 clarifies that certain cooperative banking groups are outside the scope of the top-up tax. - A decree and explanatory memorandum published on 31 Dec 2024 address the treatment of existing deferred tax assets and liabilities when calculating the ETR for the application of the top-up tax in the transition year.
- A decree published on 30 Dec 2024 includes additional implementing rules on the top-up tax, in particular, clarifications and administrative guidance issued by the OECD.
- A decree published on 23 Oct 2024 contains implementing rules on the substance-based income exclusion to be applied when calculating the amount of top-up tax.
- A decree published on 9 Jul 2024 contains implementing rules on the domestic minimum top-up tax.
- A decree published on 28 May 2024 implements the OECD safe harbours and administrative guidance into Italian law.
Notification/Filing: There is no registration requirement in Italy but there is a notification of filing entity requirement. In-scope entities also must file a GIR and a top-up tax return. A Ministerial Decree published on 6 Mar 2025 sets out the procedure for in-scope taxpayers to notify the tax authorities that the GIR will be filed centrally in another jurisdiction. The decree requires entities to submit specific information, including the identification of local entities designated to file on their behalf. A notification of the filing entity must be submitted if the GIR is filed by the UPE or designated filing entity in another jurisdiction. The notification must be made within 15 months from the end of the relevant fiscal year (18 months for the first year of application). If an in-scope MNE group has multiple Italian entities, one entity can be appointed as the designated local entity to submit the notification on behalf of all Italian CEs. Each Italian CE must submit a GIR, although a GIR is not required in Italy if the return is filed by a UPE or designated filing entity in a jurisdiction that has a qualifying competent authority agreement in effect with Italy for the relevant year. A local entity may be designated as the filing entity if there are multiple CEs in Italy. The GIR must be filed within 15 months from the end of the relevant fiscal year (18 months for the first year of application). The GIR contains information about the group entities, group structure, ETR, top-up tax allocation and attribution, and other information needed to calculate the top-up tax. A decree dated 16 Oct 2025 implements DAC9 into Italian law (DAC9 contains rules to facilitate the exchange of information relating to top-up tax returns). On 7 Aug 2025, the government approved the notification form for covered MNE groups to inform the tax authorities of their intention to delegate another group company to file the GIR. A decree (in Italian only) published on 11 Nov 2025 sets out the filing, reporting and payment obligations related to the top-up tax, taking into account the administrative guidance issued by the OECD in Jan 2025 and the model form for reporting and filing of top-up returns; the decree also includes guidance on how to complete the GIR. The return must be filed within 15 months from the end of the relevant fiscal year (18 months for the first year of application). The first payment of the top-up tax must be equal to 90% of the total tax due and paid within 11 months following the end of the relevant fiscal year. The remaining tax is to be paid within one month after the tax return filing deadline. BDO insights https://www.bdo.com.hk/getattachment/e0f93628-792a-405f-939b-9d7df125c0d4/(FINAL)-Budget-Highlights-25-26.pdf https://www.bdo.global/en-gb/insights/tax/world-wide-tax/international-corporate-tax-bytes-c8e4761d1c9f0dccfe27145099d41fae |
Jamaica | | Overview: Although the government has indicated that it intends to introduce a QDMTT, the tax authorities have announced that Jamaica is re-examining its approach taking into account the US withdrawal from the Pillar Two initiative. |
Japan | Corporation Tax Act | Overview: The 2025 tax reform package published on 31 Mar 2025 includes the introduction of a DMTT and a UTPR that are aligned with the OECD Pillar Two rules. The UTPR and QDMTT will apply for fiscal years starting on or after 1 Apr 2026. Japan enacted an IIR on 28 Mar 2023, with the measures incorporated into the Corporate Income Tax Law and applying to fiscal years starting on or after 1 Apr 2024. The 2024 Tax Reform Laws and Regulations, published on 30 Mar 2024, amended Japan’s global minimum taxation rules to incorporate additional OECD guidance into the legislation, specifically the OECD administrative guidance on the GloBE rules and the GIR. Japan’s IIR and DMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Various pieces of guidance have been published by the National Tax Agency (NTA) and the Ministry of Finance: - On 13 Sept 2024, the NTA updated the interpretative guidance on the global minimum tax law and regulations to add the QDMTT safe harbour requirements. The NTA previously updated the guidance on 9 Aug to incorporate the OECD administrative guidance and clarify the CbCR safe harbour and the substance-based income exclusion.
- On 26 Apr 2024, the NTA released explanatory notes on the global minimum tax, and a tax return for the tax was published on 12 Apr.
- The Ministry of Finance issued a technical explanation of the rules on 20 Oct 2023, and on 25 Dec 2023, the NTA released an FAQ on the minimum tax rules.
- The NTA published administrative guidance on various aspects of the domestic GloBE law on 29 Sept 2023.
Notification/Filing: There is no registration requirement in Japan, but a notification must be submitted if the GIR is not filed locally. Additionally, a GIR and top-up tax return must be filed. The notification must be filed within 15 months from the end of the relevant fiscal year (18 months for the first year). Each CE in Japan must file a GIR and if there are multiple CEs in Japan, a local entity can designated to submit the report on return of the other CEs. Each CE in Japan liable for top-up tax must submit a top-up tax return and pay the tax due. The deadline for filing the IIR, UTPR and DMTT returns is within 15 months from the day following the reporting fiscal year-end (18 months for the first time), as is the deadline for filing the GIR. BDO insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/japan-2025-tax-reform-proposal-includes-pillar-two-utpr-and-qdmtt https://www.bdo.global/en-gb/microsites/tax-newsletters/corporate-tax-news/issue-65-february-2023/japan-global-minimum-tax-to-be-introduced-under-2023-tax-reform-along-with-easing-of-cfc-rules |
Jersey | Multinational Taxation (Global Anti-Base Erosion – IIR Tax) (Jersey) Law 2025 | Overview: In a press release dated 22 Oct 2024, the government announced that the Jersey States Assembly adopted the draft legislation (Multinational Taxation (Global Anti-Base Erosion – IIR Tax) (Jersey) Law 2025) to implement a Pillar Two IIR and a multinational corporate income tax (MCIT), aligned with the OECD GloBE model rules. There currently are no plans for a UTPR. The rules apply for fiscal years starting as from 1 Jan 2025 with further primary tax legislation expected. Jersey plans to create an OECD-compliant qualifying refundable tax credit to provide incentives for business growth following the adoption of the Pillar Two rules. In an order dated 10 Dec 2024, the Minister for Treasury and Resources established that for a reporting entity of an MNE group to apply for an exemption from the MCIT, its MCIT net GloBE income of a fiscal year must be less than the minimum threshold amount of GBP 100,000. Jersey’s IIR is treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: Jersey has registration and notification requirements, and in-scope entities are required to file a GIR and a top-up tax return. Each Jersey CE must be registered with the Comptroller and information reported in the form and manner specified by the Comptroller. Registration must be completed via the government portal before the end of the first fiscal year the MNE group falls within the scope of the global minimum tax rules. The GIR and the IIR return must be submitted within 15 months after the end of the relevant fiscal year (18 months in the first fiscal year of application). The latter must be in the form and manner specified by the Comptroller. These returns must be submitted by the highest ranking group entity that is resident in Jersey, and if there is no such entity, a domestic reporting entity must be designated to fulfill these obligations. The Comptroller must be notified by the reporting entity whether that entity is the “qualifying” entity in relation to the MNE group. If it is not, that entity must disclose the identity of the entity designated to file the GIR, the jurisdiction in which the filing entity is located and the jurisdiction in which the GIR will be filed. The reporting entity is required to submit the DMTT return to the Comptroller within 12 months after the end of the fiscal year. As with the GIR and IIR return, the return must be filed by the highest ranking group entity resident in Jersey. If there is none, the Comptroller can designate a Jersey CE of the group to file the DMTT return. Other: The governments of Guernsey, Jersey and the Isle of Man announced on 19 May 2023 that they had jointly agreed to adopt the Pillar Two framework and that they would adopt the IIR and a DMTT to provide for a 15% effective tax rate for large in-scope MNEs. In May 2024, the three islands announced a timeline to begin the relevant legislative procedures. |
Kenya | Tax Laws (Amendment) Act 2024 | Overview: The Tax Laws (Amendment) Act 2024 received the Kenyan president’s assent on 11 Dec 2024 and became effective on 27 Dec. The legislation, which amends the Income Tax Act, introduces a 15% domestic minimum top-up tax (DMTT) that is generally in alignment with the OECD Pillar Two rules. There is no IIR or QDMT. The DMTT applies to Kenya-based members of an in-scope MNE group (i.e., a group with annual revenue of EUR 750 million or more in the consolidated financial statements of the UPE in at least two of the four years of income immediately preceding the tested year of income. Kenyan group members must pay the top-up tax to increase their ETRs to 15% if they fall below that threshold. The DMTT applies to fiscal years starting on or after 1 Jan 2025. The Kenya Revenue Authority (KRA) released draft Income Tax (Minimum Top Up Tax) Regulations, 2025 on 3 Nov 2025 for public consultation. The regulations address the operation of the DMTT, as well as compliance obligations, and adopt the OECD safe harbours and administrative guidance. Notification/Filing: Kenya does not have a registration requirement but there is a notification requirement and in-scope entities must file a GIR and a top-up tax return. The Commissioner of the KRA must be notified of the designated filing entity within 60 days of publication of the proposed regulations or within six months from the first day of the year of income for any subsequent years. A covered person must submit a top-up tax return by the last day of the sixth month following the end of the income year. The GIR must be filed within 15 months after the end of the relevant fiscal year (18 months after the end of the fiscal year in which a group initially falls within the scope of application of the minimum tax rules). |
Korea | Law for the Coordination of International Tax Affairs (in Korean) | Overview: The global minimum tax was introduced in the Law for the Coordination of International Tax Affairs on 31 Dec 2022, making Korea the first country to codify the GloBE rules. The Korean Pillar Two rules generally follow the OECD model rules. Korea has introduced both an IIR and supplementary rules for income inclusion (UTPR). The IIR became effective for fiscal years starting on or after 1 Jan 2024 and the effective date for the UTPR was delayed by a year to 1 Jan 2025. A QDMTT was subsequently included in the 2025 tax law amendments proposal released on 31 Jul 2025 and applies for fiscal years starting on or after 1 Jan 2026. A presidential decree enacted in Jan 2024 added a new chapter to the Enforcement Decree of the Law for the Coordination of International Tax Affairs, which contains details on the Korean GloBE rules. The decree was further amended in Feb 2025 to incorporate the OECD administrative guidance from Jun 2024 and address the top-up tax forms. Korea’s IIR is treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: Korea has a notification requirement, as well as an obligation to submit a GIR and a top-up tax return. A Korean CE is required to file a GIR within 15 months from the last day of the relevant fiscal year (18 months for the first year of application) unless a foreign CE in the same MNE group files a GIR in another jurisdiction. The top-up tax return must be filed within the same timeline. BDO Insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/korea-implementation-of-utpr-delayed |
Kuwait | Decree No. 157 of 2024 (in Arabic only) | Overview: A decree (Decree No. 157 of 2024) published on 31 Dec 2024 introduces a 15% domestic minimum top-up tax (DMTT) at an effective rate of 15% that is aligned with the OECD Pillar Two GloBE Rules and that will help Kuwait collect tax revenue that may otherwise be collected by other jurisdictions through an IIR or UTPR. The decree does not include an IIR or a UTPR, but it does include safe harbours. The decree is effective for fiscal years starting on or after 1 Jan 2025 and ensures that in-scope MNEs pay a minimum tax rate of at least 15% on their profits. The DMTT decree applies to all entities in Kuwait, whether UPEs or CEs, e.g., subsidiaries or permanent establishments (PEs) of a group that meet both of the following criteria: (i) the group is an MNE group (i.e., it is present in more than one jurisdiction through a subsidiary, branch, PE or similar form of presence); and (ii) the UPE of the group has a consolidated revenue of at least EUR 750 million in at least two out of the prior four accounting years. The decree also applies to stateless entities and joint ventures that are owned 50% or more by an in-scope MNE group. The Ministry of Finance issued Executive Regulations on 29 Jun 2025 that set out the registration and filing requirements, the safe harbour and simplification rules, administrative penalties and how Kuwait's DMTT interacts with the QDMTT under global Pillar Two rules. Notification/Filing: Kuwait has a registration requirement, and in-scope entities must submit a GIR and a top-up tax return. In-scope taxpayers must register with the Kuwaiti tax authorities within 120 days from the date of commencement of in-scope activities and MNE groups must register for DMTT purposes within nine months from the date the law enters into effect. The GIR may require a UPE to submit a GIR within 15 months of the end of the relevant tax period. A Kuwaiti CE must file a domestic top-up tax return and pay the top-up tax within 15 months of the end of the relevant tax period, even if the tax due is zero. On 16 Jul 2025, the Ministry of Finance announced the launch of an electronic registration service for in-scope companies. BDO Insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/kuwait-regulations-clarify-domestic-minimum-top-up-tax-for-mnes https://www.bdo.com.kw/en-gb/insights/featured-insights/kuwait-tax-alert-pillar-two-regulations-issued https://www.bdo.global/en-gb/insights/tax/world-wide-tax/kuwait-pillar-two-domestic-top-up-tax-enacted https://www.bdo.global/en-gb/insights/tax/world-wide-tax/kuwait-15-business-profit-tax-proposed |
Latvia | Law on ensuring a global minimum tax level for large corporate groups | Overview: The law that partially transposes the EU directive into Latvian law, the Law on ensuring a global minimum tax level for large corporate groups, was published in the official gazette on 20 Jun 2024 and applies as from 21 Jun. The law includes an IIR and UTPR but no DMTT. Latvia has notified the European Commission that it intends to postpone the application of the IIR and the UTPR for six consecutive fiscal years as provided in article 50(1) of the directive, which allows EU member states with 12 or fewer UPEs of in-scope MNEs to delay the application of the rules. However, a member state that opts to make the election still must transpose all the other relevant directive measures to enable taxpayers and other EU member states and third countries to properly apply the system. As a result, the IIR and UTPR will not become effective until 2030. Five member states—Estonia, Latvia, Lithuania, Malta and Slovakia—have exercised the election to defer application of the IIR and UTPR. Notification/Filing: Compliance obligations are set out even though Latvia is deferring implementation of Pillar Two until 2030. Latvia’s implementing legislation does not address registration, notification or top-up tax return filing requirements. However, it does require the UPE of a group located in Latvia to appoint a designated filing entity in another EU member state that will be responsible for filing a GIR. If there is no CE in another member state, one in a third country can be appointed if that jurisdiction has a qualifying competent authority agreement in effect with Latvia for the automatic exchange of top-up tax information returns. At the request of a designated CE, CEs in Latvia must ensure the submission of information at its disposal that is necessary to prepare the GIR within 12 months after the last day of the relevant fiscal year. Other: On 12 Dec 2025, Estonia, Latvia, Lithuania, Malta and the Slovak Republic submitted a joint statement to the EU Finance Ministers requesting a review of the EU's implementation of the Pillar Two global minimum tax rules and specifically asked that the option to postpone application of the minimum tax be extended for an additional six years. On 11 Dec 2025, the European Commission announced that it has closed the infringement proceedings against Latvia for failure to notify the Commission about measures transposing the EU global minimum taxation directive into its domestic law by the 31 Dec 2023 deadline. Infringement proceedings had been initiated against nine member states.
BDO insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/european-union-five-eu-member-states-elect-to-delay-application-of-iir-and-utpr |
Liechtenstein | Law of 10 November 2023 on the minimum taxation of large corporate groups | Overview: The law implementing the Pillar Two rules into domestic law, the Law of 10 November 2023 on the minimum taxation of large corporate groups, was published in the official gazette on 22 Dec 2023 and is effective as from 1 Jan 2024 (click here for the government announcement). The minimum tax takes the form of a “supplementary tax” (i.e., an IIR and a QDMTT) that kicks in where a domestic company does not pay at least a 15% minimum tax rate. The IIR and QDMTT are effective for fiscal years starting on or after 31 Dec 2024. A UTPR is expected to be included in a separate ordinance. An ordinance on the application of the legislation, which became effective on 29 Mar 2024, provides details on filing the GloBE tax and information return, as well as clarifications, such as providing that the GloBE model rules are to be interpreted and applied per the OECD Commentary and administrative guidance and that the OECD safe harbours apply in Liechtenstein. Liechtenstein’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: There is a registration requirement in Liechtenstein for in-scope entities to notify the tax authorities that they fall within the scope of the rules. In-scope entities also must file a GIR and a top-up tax return. Rules published on 13 Dec 2024 introduce the notification requirement for in-scope Liechtenstein entities, which applies for fiscal years starting on or after 1 Jan 2024, and a GloBE registration form was published on 9 Jan 2025. MNE groups falling within the scope of the Pillar Two requirements were required to register in Liechtenstein by 30 Jun 2025 using the GloBE registration form. The MNE group must identify the CEs in Liechtenstein and provide their names, addresses and status (UPE, partially owned parent entity, etc.). The group also must specify the CE that will submit the QDMTT and IIR tax return and which group entity will submit the GIR. Each Liechtenstein CE must submit a GIR, although a GIR is not required in Liechtenstein if the return is filed by a UPE or designated filing entity in a jurisdiction that has a qualifying competent authority agreement in effect with Liechtenstein for the relevant year. A local entity may be designated as the filing entity if there are multiple CEs in Liechtenstein. The GIR must be filed within 15 months from the end of the relevant fiscal year (18 months for the first year of application). The GIR contains information about the group entities, group structure, ETR, top-up tax allocation and attribution, and other information needed to calculate the top-up tax. A top-up tax return must be submitted. On 22 Apr 2025, the Liechtenstein tax authorities extended the deadline to submit the first Liechtenstein QDMTT/IIR return from 31 Dec 2025 to 30 Jun 2026 and extended the deadline to register in Liechtenstein from 30 Jun 2025 to 31 Dec 2025. The minimum taxation law has been amended to include a list of partner states with which Liechtenstein will exchange GIRS starting from the reporting fiscal year 2024. BDO insights https://www.bdo.global/en-gb/microsites/tax-newsletters/corporate-tax-news/issue-65-february-2023/international-corporate-tax-bytes https://www.bdo.global/en-gb/insights/tax/world-wide-tax/liechtenstein-pillar-two-globe-registration-launched |
Lithuania | Law on Ensuring the Minimum Level of Taxation for Entity Groups | Overview: The law transposing the EU minimum taxation directive into domestic law was finalized on 21 Jun 2024 and is effective as from 1 Jul. On 10 Jun 2024, the tax authorities released guidance on the procedures for making the required notifications under the rules. The law includes an IIR and UTPR but no QDMTT. Lithuania will not apply the IIR and UTPR until 2030. The country has notified the European Commission that it intends to postpone the application of the IIR and the UTPR for six consecutive fiscal years as provided in article 50(1) of the directive, which allows EU member states with 12 or fewer UPEs of in-scope MNEs to delay the application of the rules. However, a member state that opts to make the election still must transpose all the other relevant directive measures to enable taxpayers and other EU member states and third countries to properly apply the system. Five member states—Estonia, Latvia, Lithuania, Malta and Slovakia—have exercised the election to defer application of the IIR and UTPR. The government has proposed incentives for research, technological and experimental development investments to support companies that can no longer benefit from incentives due to the Pillar Two legislation, but the changes have not yet been approved. The legislation has been integrated into the Law on Tax Administration and the Law on Corporate Income Tax. Notification/Filing: Compliance obligations are set out even though Lithuania is deferring implementation of Pillar Two until 2030. Lithuania’s implementing legislation does not address registration or top-up tax return filing requirements. However, a Lithuanian CE entity must submit a notification of the commencement of the initial phase of activities within 15 months from the end of the first year the group falls within the scope of the rules and one CE can file the notification on behalf of all relevant CEs. MNE groups in the initial phase of activities are typically those located in no more than six jurisdictions and with tangible assets outside their reference jurisdiction that do not exceed EUR 50 million. There are reporting obligations for fiscal years beginning on or after 31 Dec 2023, i.e., notification of a designated reporting entity, notification confirming data needed to prepare the GIR. In-scope entities are to use the GloBE rules documents published by the OECD for compliance purposes. Other: On 12 Dec 2025, Estonia, Latvia, Lithuania, Malta and the Slovak Republic submitted a joint statement to the EU Finance Ministers requesting a review of the EU's implementation of the Pillar Two global minimum tax rules and specifically asked that the option to postpone application of the minimum tax be extended for an additional six years. On 11 Dec 2025, the European Commission announced that it has closed the infringement proceedings against Lithuania for failure to notify the Commission about measures transposing the EU global minimum taxation directive into its domestic law by the 31 Dec 2023 deadline. Infringement proceedings had been initiated against nine member states. |
Luxembourg | Law of 22 December 2023 relating to the minimum effective taxation with a view to transposing Council Directive (EU) 2022/2523 of 15 December 2022 to ensure a minimum level of worldwide taxation for multinational enterprise groups and large national groups in the Union | Overview: The legislation that transposes the EU global minimum taxation directive into Luxembourg law was published in the official gazette on 22 Dec 2023 and became effective on 31 Dec. Legislation published in the official gazette on 23 Dec 2024 and that applies to fiscal years starting on or after 31 Dec 2023 incorporates the 2023 OECD administrative guidance into Luxembourg law. The legislation includes an IIR and UTPR, and Luxembourg has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Luxembourg resident entities on a consolidated basis. The IIR and QDMTT apply to fiscal years starting on or after 31 Dec 2023 and the UTPR applies to fiscal years starting on or after 31 Dec 2024. Luxembourg’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. The authorities have issued several sets of guidance on the Pillar Two legislation: - A Grand-ducal regulation published in the official gazette on 23 Dec 2024 and that applies to tax years starting on or after 31 Dec 2024 contains new rules on the functional reporting currency for applying the Pillar Two legislation.
- On 25 Mar 2024, the tax authorities published FAQs that clarify various aspects of the legislation, such as deferred tax assets and liabilities and transitional rules.
- A Grand-Ducal regulation adopted on 24 Jul 2024 sets out the rules relating to functional currency, tax credits and qualified holdings for applying the Minimum Taxation Act.
Notification/Filing: Luxembourg has a registration requirement and a notification of filing entity requirement. In-scope entities also must file a GIR and a top-up tax return. Each CE in Luxembourg must register with the tax authorities within 15 months from the end of the relevant fiscal year (18 months for the first year of application) A notification of the filing entity must be submitted if the GIR is filed by the UPE or designated filing entity in another jurisdiction. The notification must be made within 15 months from the end of the relevant fiscal year (18 months for the first year of application). If an in-scope MNE group has multiple Luxembourg entities, one entity can be appointed as the designated local entity to submit the notification on behalf of all Luxembourg CEs. On 24 Jul 2025, the Council of Ministers adopted a draft Grand-Ducal regulation to implement a standard template for the Pillar Two information return. Each Luxembourg CE must submit a GIR, although a GIR is not required in Luxembourg if the return is filed by a UPE or designated filing entity in a jurisdiction that has a qualifying competent authority agreement in effect with Luxembourg for the relevant year. A local entity may be designated as the filing entity if there are multiple CEs in Luxembourg. The GIR must be filed within 15 months from the end of the relevant fiscal year (18 months for the first year of application). Luxembourg CEs that are subject to the IIR, UTPR or QDMTT must submit a top-up tax return within 15 months from the end of the relevant fiscal year (18 months for the first year of application). A local entity may be designated as the filing entity if there are multiple CEs in Luxembourg. Tax must be paid within one month after the top-up tax is filed. |
North Macedonia | Law on global minimum corporate income tax | Overview: A law published on 3 Jan 2025 introduces a minimum global profit tax that is generally aligned with the EU directive. The legislation includes an IIR, a UTPR and a QDMTT that apply to resident MNEs of groups with annual consolidated revenue of at least EUR 750 million in at least two of the preceding four fiscal years. The IIR and UPTR apply for the fiscal year starting on 1 Jan 2024 and the UTPR applies to fiscal years starting on or after 1 Jan 2025. North Macedonia’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. The law does not adopt the OECD administrative guidance, except for references to the safe harbours. Notification/Filing: There is a notification requirement, as well as filing requirements for the GIR and top-up tax return. In-scope taxpayers are required to notify the tax authorities of the entity designated to file the GIR on behalf of the group. The form, GIR and top-up tax return must be filed within 15 months after the end of the relevant fiscal year (18 months after the end of the fiscal year in which a group initially falls within the scope of application of the minimum tax rules). The government is expected to issue guidance on the operation of the rules. |
Malaysia | Finance (No. 2) Act 2023 (The Pillar Two rules have been incorporated into Malaysian law by inserting a new Part XI - Implementation of Domestic Top-Up Tax and Multinational Top-Up Tax with 19 chapters into the Income Tax Act 1967 and by referring to this new Part in the Petroleum (Income Tax) Act 1967 and Labuan Business Activity Tax Act 1990) | Overview: Finance (No. 2) Act 2023, which contains the legislative provisions for the implementation of the OECD Pillar Two rules in Malaysia, was gazetted on 29 Dec 2023. Finance Bill 2024 amended the rules by revising some definitions and clarifying some calculations. Malaysia’s Pillar Two legislation includes an IIR—called the “Multinational Top-Up Tax”—and a domestic minimum tax (intended to be a QDMTT). There is no UTPR. The rules are effective as from 1 Jan 2025, rather than 1 Jan 2024 as previously announced. The government has released an implementation timeline and FAQs on the global minimum tax rules. One of the clarifications in the FAQs is that Zakat is not considered a “covered tax” for purposes of the GloBE rules. On 2 Dec 2024, the tax authorities released updated guidelines on the implementation of the rules and on 6 Dec further updated the FAQs. Guidance released on 2 Dec 2024 and that applies as from 1 Jan 2025 explains the implementation of the Pillar Two legislation and outlines the tax authorities’ interpretation and administration, including policies and procedures. However, in the event of any inconsistencies, the OECD GloBE rules take precedence. Malaysia’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: Malaysia requires taxpayers to answer questions about its Pillar Two status on the corporate tax form and to submit a notification of filing entity. In-scope entities also must file a GIR and a top-up tax return. A notification of the filing entity must be submitted if the GIR is filed by the UPE or designated filing entity in another jurisdiction that has an information exchange agreement in effect with Malaysia for the relevant year. The notification must be made within 15 months from the end of the relevant fiscal year (18 months for the first year of application). If an in-scope MNE group has multiple Malaysian entities, one entity can be appointed as the designated local entity to submit the notification on behalf of all Malaysian CEs. A CE of an MNE group (or designated CE) must submit a GIR no later than 15 months from the last day of the reporting fiscal year. The return must include data on the CEs, the overall structure of the group, the ETR of each jurisdiction and DMTT or multinational top-up tax of each CE, etc. A GIR will not be required in Malaysia if it is filed by a UPE or designated filing entity located in a jurisdiction that has a qualifying competent authority agreement in effect with Malaysia for the reporting fiscal year. If a designated entity is appointed, the tax authorities must be notified no later than 15 months from the last day of the reporting fiscal year. Each CE of an in-scope MNE group must submit the top-up tax return for each reporting fiscal year no later than 15 months from the last day of the reporting fiscal year. BDO insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/global-minimum-tax-to-apply-as-from-2025 |
Malta | European Union Global Minimum Level of Taxation For Multinational Enterprises Groups and Large-Scale Domestic Groups Regulations 2024 | Overview: A legal notice published on 20 Feb 2024 transposes the EU minimum taxation directive into Malta’s domestic law, with the rules coming into force on 31 Dec 2023 and are applicable to fiscal years starting on or after that date. On 27 Feb 2024, the tax authorities released a guidance note on the rules. The rules are deemed to come into force on 31 Dec 2023 but are restricted to the transposition of Chapters I, VIII and IX and of the directive, as the minimum measures that are relevant to ensure the proper functioning of the global minimum level of taxation for MNE groups and large-scale domestic groups, which is required. Malta has postponed the application of the IIR and the UTPR for six years as provided in article 50(1) of the EU directive. Article 50(1) allows EU member states with 12 or fewer UPEs of in-scope MNEs to delay the application of the rules. Five member states—Estonia, Latvia, Lithuania, Malta and Slovakia—have exercised the election to defer application of the IIR and UTPR. Malta is not introducing a QDMTT for the time being. Notification/Filing: Some compliance obligations are set out even though Malta is deferring implementation of Pillar Two until 2030. Malta’s implementing legislation does not include a registration requirement but there is a notification of filing entity requirement, and the legislation does not address the GIR. A UPE of an MNE group in Malta must nominate a designated filing entity in another member state or, if the group does not have a CE in another member state, in a third-country jurisdiction that has, for the reporting fiscal year, a qualifying competent authority agreement in effect with Malta. Other: On 12 Dec 2025, Estonia, Latvia, Lithuania, Malta and the Slovak Republic submitted a joint statement to the EU Finance Ministers requesting a review of the EU's implementation of the Pillar Two global minimum tax rules and specifically asked that the option to postpone application of the minimum tax be extended for an additional six years. On 3 Oct 2024, the European Commission closed the infringement proceedings against Malta for failure to notify the Commission about measures transposing the EU global minimum taxation directive into their domestic laws by the 31 Dec 2023 deadline. BDO insights https://www.bdo.com.mt/en-gb/news/news-in-2024/pillar-2-global-guidance-note https://www.bdo.global/en-gb/insights/tax/world-wide-tax/malta-pillar-two-rules-enacted https://www.bdo.global/en-gb/insights/tax/world-wide-tax/european-union-five-eu-member-states-elect-to-delay-application-of-iir-and-utpr |
Mauritius | Income Tax Act | Overview: The 2025 Finance Act published on 9 Aug 2025 introduced a QDMTT on subsidiaries and holding companies of MNEs resident in Mauritius on income derived as from 1 Jul 2025 where their ETR is less than 15%. The QDMTT applies to years of assessment starting as from 1 Jul 2025. The domestic rules, which are consistent with the OECD rules, include substance-based income exclusions and safe harbour provisions. Notification/Filing: There is no registration requirement in Mauritius, but a resident company must notify the tax authorities of the identity of the Mauritius-resident designated person that will file the QDMT tax return and pay the tax due within six months from the end of the MNE group’s fiscal year. The QDMTT return must also be filed within 15 months of the end of the fiscal year (18 months for the first year). The Mauritius Revenue Authority (MRA) issued a Communique on 29 Oct 2025, which clarified and extended the QDMTT filing deadline. Because the Mauritius QDMTT applies for years of assessment starting on or after 1 Jul 2025 for resident CEs, the rules covered CEs of MNE groups with a fiscal year ending on or after 1 Jan 2025, meaning that the notification deadline already passed for fiscal years that ended earlier in 2025. As a result, the MRA extended the deadline to 30 Nov 2025 for notifications due before that date. BDO insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/mauritius-2025-26-budget-proposals-include-domestic-minimum-top-up-tax |
Netherlands | Minimum Tax Act 2024 | Overview: The bill that transposes the EU global minimum taxation directive into Dutch law was enacted on 27 Dec 2023 and is effective as from 31 Dec. The Dutch tax authorities have created a database that contains information on the directive and the rules on global minimum taxation and on 2 Sept 2025 the authorities published a lengthy Q&A on the Minimum Tax Act 2024 (in Dutch only). The legislation includes an IIR and a UTPR, and the Netherlands has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Dutch resident entities on a consolidated basis. The IIR and QDMTT apply for fiscal years starting on or after 31 Dec 2023 and the UTPR applies for fiscal years starting on or after 31 Dec 2024. The Netherlands’ IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. The tax authorities released a clarification on 11 Dec 2025 of the treatment of corporate income tax charges arising before the Minimum Taxation Act 2024 became effective and subsequently recognized. A decree published on 23 Dec 2024 (Minimum Tax Executive Decree 2024) implements various parts of the 2023 OECD administrative guidance into Dutch law and applies retroactively from 31 December 2023. Notification/Filing: There is no registration requirement in Italy but there is a notification of filing entity requirement. In-scope entities also must file a GIR and a top-up tax return. A notification of the filing entity must be submitted if the GIR is filed by the UPE or designated filing entity in another jurisdiction within 15 months from the end of the relevant fiscal year (18 months for the first year of application). If an in-scope MNE group has multiple Dutch entities, one entity can be appointed as the designated local entity to submit the notification on behalf of all Dutch CEs. Each Dutch CE must submit a GIR, although a GIR is not required in the Netherlands if the return is filed by a UPE or designated filing entity in a jurisdiction that has a qualifying competent authority agreement in effect with the Netherlands for the relevant year. A local entity may be designated as the filing entity if there are multiple CEs in the Netherlands. The GIR must be filed within 15 months from the end of the relevant fiscal year (18 months for the first year of application). However, based on changes to the Minimum Taxation Act, a GIR return does not have to be filed before 31 Jun 2026. The GIR contains information about the group entities, group structure, ETR, top-up tax allocation and attribution, and other information needed to calculate the top-up tax. The top-up tax return must be filed within 17 months after the end of the fiscal year (20 months for the first reporting year), and payment of the tax is due within the same time frame. BDO insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/netherlands-changes-proposed-to-minimum-tax-and-subject-to-tax-rules |
New Zealand | Taxation (Annual Rates for 2023–24, Multinational Tax, and Remedial Matters) Act | Overview: The legislation that implements the Pillar Two rules (i.e., Taxation (Annual Rates for 2023–24, Multinational Tax, and Remedial Matters) Act) was passed on 27 Mar 2024. The top-up tax consists of an IIR and a UTPR, as well as a domestic IIR for domestic groups that is similar to a QDMTT. The IIR and UTPR apply for fiscal years starting as from 1 Jan 2025 and the domestic IIR applies for fiscal years starting as from 1 Jan 2026. New Zealand’s IIR is treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: New Zealand has both a registration and notification requirement. In-scope entities are required to submit a GIR and a top-up tax return. Each CE in New Zealand of an MNE group must register with Inland Revenue within six months after the first fiscal year of falling within the scope of the rules. A New Zealand CE or designated local entity must file a notification of the filing entity if the GIR is not filed in New Zealand within 15 months from the end of the relevant fiscal year (18 months for the first year of application). A CE of an MNE group (or designated CE) must submit a GIR for each fiscal year in which the entity is an entity that falls within the scope of the rules within 15 months after the end of the relevant fiscal year (18 months for the first year of application). The GIR contains information about the group entities, group structure, ETR, top-up tax allocation and attribution, and other information needed to calculate the top-up tax. However, a GIR is not required to be filed in New Zealand if it is filed by the UPE or designated filing entity in a jurisdiction that has concluded a qualifying competent authority agreement with New Zealand for the relevant year. An annual multinational top-up tax return must be filed by a CE within 16 months after the end of the fiscal year (20 month for the first year), with the tax paid at the time of filing. |
Nigeria | Nigeria Tax Act 2025 | Overview: The Nigeria Tax Act signed by the president on 26 Jun 2025 and that applies as from 1 Jan 2026, introduces a 15% minimum top-up tax mechism that is aligned with the OECD Pillar Two rules. Under the provision, if an in-scope company’s ETR is less than 15% in any year of assessment, the company must recompute and pay an additional top-up tax to bring the ETR up to 15%. The tax applies to fiscal years starting on or after 1 Jan 2026. The rule applies to companies that are CEs of an MNE group, foreign subsidiaries of Nigerian parent entities and any company with aggregate turnover of NGN 20 billion or more in the relevant year of assessment. Notification/Filing: There is currently no data available on compliance requirements. |
Norway | Act relating to supplementary tax on undertaxed income in groups | Overview: The law that implements the global minimum tax rules into Norwegian law (Supplementary Tax Act) was published in the official gazette on 12 Jan 2024 and applies as from that date. The law includes an IIR and QDMTT, but not a UTPR. The IIR and QDMTT apply for fiscal years starting on or after 31 Dec 2023. A UTPR was included in the 2025 national budget and applies for fiscal years starting on or after 31 Dec 2024. A consultation between Jun and Aug 2025 on proposed revisions to the Pillar Two law to adapt Norway’s rules more closely with the OECD’s Jun 2024 and Jan 2025 administrative guidance and correct technical errors in the legislation. The revised 2024 national budget clarifies the application of the minimum tax rules with Norway’s ground rent tax. Norway’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: Norway does not have a registration requirement, but a notification of the filing entity is required. In-scope entities must file a GIR and top-up tax return. If the GIR is not filed locally, the Norwegian CE (or designated local entity) must submit a notification of the filing entity to the tax authorities within 15 months of the end of the relevant fiscal year (18 months for the first year of application). Each CE in Romania must file a GIR, although if there are multiple Romanian CEs, a local entity may be designated to submit the GIR on behalf of the other Romanian CEs. The GIR must be filed within 15 months after the end of the relevant fiscal year (18 months for the first year of application). A GIR is not required if one is filed by the UPE or a designated filing entity located in a jurisdiction that has concluded an automatic exchange of the annual GIR agreement with Romania for the reporting fiscal year. A Norwegian CE liable for supplementary tax must file a supplementary tax return within one month from the deadline for filing the GIR, with tax paid within three weeks after the supplementary tax return deadline. |
Oman | Royal Decree 70 of 2024 (in Arabic only) | Overview: Royal Decree 70 of 2024 issued by the Sultanate of Oman on 31 Dec 2024 implements Pillar Two rules, fulfilling Oman’s commitment to introduce a minimum tax as a participant under the Inclusive Framework. Oman’s legislation is aligned with the OECD GloBE rules and introduces an IIR and a domestic minimum top-up tax (DMTT) in the form of a “Supplemental Tax.” The IIR and DMTT apply for fiscal years starting on or after 1 Jan 2025. Oman’s tax authorities will be issuing Executive Regulations that will contain detailed guidance that will address calculation of the tax, safe harbours, procedures, etc. Oman has an existing corporate income tax regime with a headline rate of 15%. Notification/Filing: The notification and filing requirements will be set out in the Executive Regulations.
BDO Insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/oman-pillar-two-legislation-in-effect |
Poland | Law on top-up tax on constituent entities of multinational and domestic groups (in Polish only) | Overview: The bill transposing the EU minimum taxation directive into Polish law was signed by the president on 15 Nov 2024, with the new rules applying as from 1 Jan 2025. A consultation on the bill was held in Apr and May 2024. The legislation includes an IIR and UTPR and Poland has opted to adopt a QDMTT. It also includes safe harbours. Transitional provisions provide for the possibility of retroactive application of the measures as from 1 Jan 2024. The IIR, UTPR and QDMTT apply for fiscal years starting on or after 1 Jan 2025. Poland’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. The government intends to adapt the tax relief for R&D activities to the GloBE system; if approved, these measures would become effective as from 1 Jan 2026, with possible retroactive application to the current fiscal year. There are plans to amend the Pillar Two legislation to incorporate the OECD administrative guidance from Jun 2024 and Jan 2025, which includes guidance on deferred tax liabilities, allocation of taxes, treatment of intermediary entities and recognizing deferred tax assets that arise from tax reliefs (e.g., R&D incentives). Notification/Filing: The Polish tax authorities must be notified of the entity designated to file the GIR on behalf of the group. This Norway does not have a registration requirement, but a notification of the filing entity is required. In-scope entities must file a GIR and top-up tax return. A notification of the filing entity must be submitted if the GIR is filed by the UPE or designated filing entity in another jurisdiction for the relevant year. The notification must be made within 15 months from the end of the relevant fiscal year (18 months for the first year of application). This election can be made for a period of up to five years and the notification must be submitted to the tax authorities by the deadline for filing the top-up tax return. Each Polish CE must submit a GIR, although a GIR is not required in Poland if the return is filed by a UPE or designated filing entity in a jurisdiction that has a qualifying competent authority agreement in effect with Poland for the relevant year. A local entity may be designated as the filing entity if there are multiple CEs in Poland. The GIR must be filed within 15 months from the end of the relevant fiscal year (18 months for the first year of application). H The GIR contains information about the group entities, group structure, ETR, top-up tax allocation and attribution, and other information needed to calculate the top-up tax. Additional self-assessment returns for the IIR, UTPR and QDMTT must be filed by the end of the 18th month following the end of the tax year (the 21st month for the first transitional year). A consultation was held in Sept 2025 on draft Pillar 2 notifications and top-up tax returns for consultation and a consultation was opened on 5 Nov 2025 on a draft GIR return. A Compensatory Taxation Council has been set up to provide guidance and issue tax rulings for in-scope taxpayers, with fees charged for these services. Other: On 17 Dec 2025, Poland withdrew its opposition to the proposed side-by-side system that would exempt US companies from the Pillar Two rules following meetings with US representatives. Estonia and the Czech Republic also have agreed to accept the rules. On 11 Dec 2025, the European Commission announced that it has closed the infringement proceedings against Poland for failure to notify the Commission about measures transposing the EU global minimum taxation directive into its domestic law by the 31 Dec 2023 deadline. Infringement proceedings had been initiated against nine member states. |
Portugal | Law no. 41/2024 of 8 November, transposing Directive (EU) 2022/2523, Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union into the internal legal order | Overview: The bill transposing the EU minimum taxation directive into domestic law was published on 8 Nov 2024, following promulgation by the president and parliamentary approval. The legislation includes an IIR and UTPR, and Portugal has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Portuguese resident entities on a consolidated basis. Also included is an option to apply a transitional CbCR safe harbour for tax years commencing on or before 31 Dec 2026 and ending on or before 30 Jun 2028. The IIR and QDMTT apply for fiscal years starting on or after 31 Dec 2024 and the UTPR will apply for fiscal years starting on or after 31 Dec 2025. Portugal’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: Portugal has a registration requirement and a notification of filing entity requirement. In-scope entities also must file a GIR and a top-up tax return. Each CE in Portugal that is subject to the global minimum tax rules must register its status as a reporting CE or the CE of the MNE group. Additionally, the UPE or designated reporting entity must be registered and changes have to be reported. Registration is required within nine months after the end of the fiscal year tax in which the group becomes subject to the Pillar Two rules or where there is a change to the registration information. An ordinance published on 2 Sept 2025 (in Portuguese only) approves the registration declaration form and instructions for completion. A notification of the filing entity must be submitted if the GIR is filed by the UPE or designated filing entity in another jurisdiction that has an information exchange agreement in effect with Portugal for the relevant year. The notification must be made within 15 months from the end of the relevant fiscal year (18 months for the first year of application). If an in-scope MNE group has multiple Portuguese entities, one entity can be appointed as the designated local entity to submit the notification on behalf of all Portuguese CEs. Each Portuguese CE must submit a GIR, although a GIR is not required in Portugal if the return is filed by a UPE or designated filing entity in a jurisdiction that has a qualifying competent authority agreement in effect with Portugal for the relevant year. A local entity may be designated as the filing entity if there are multiple CEs in Portugal. The GIR must be filed within 15 months from the end of the relevant fiscal year (18 months for the first year of application). The GIR contains information about the group entities, group structure, ETR, top-up tax allocation and attribution, and other information needed to calculate the top-up tax. The supplementary tax return must be filed within 15 months after the end of the fiscal year (18 months for the first reporting year), and payment of the tax is due within the same time frame. Other: On 11 Dec 2025, the European Commission announced that it has closed the infringement proceedings against Portugal for failure to notify the Commission about measures transposing the EU global minimum taxation directive into its domestic law by the 31 Dec 2023 deadline. Infringement proceedings had been initiated against nine member states.
|
Puerto Rico | | Overview: Puerto Rico plans to introduce a QDMTT that would allow Puerto Rico to collect the tax domestically. An IIR or UTPR are not under consideration. Draft legislation approved by the House of Representatives on 31 Oct 2023 was rejected by the senate and sent back to the House for further reconsideration, but agreement was not reached. |
Qatar | Law 22 of 2024 (in Arabic only) | Overview: The government published a law on 27 Mar 2025 (Law 22 of 2024) that amends the Qatar Income Tax Law (ITL) to introduce rules that are consistent with the OECD GloBE Rules. The amended sections of the ITL apply only to in-scope entities and are effective as from 1 Jan 2025 and applies to fiscal years starting on or after 1 January 2025. The measures include an IIR, a UTPR and QDMTT that apply to MNE groups operating in Qatar with consolidated annual revenue of EUR 750 million or more in two of the preceding four fiscal years. The IIR, UTPR and QDMTT apply for fiscal years starting on or after 1 Jan 2025. The amended rules incorporate the OECD commentary and administrative guidance, as well as relevant safe harbours. The government is expected to issue Executive Regulations and/or other guidance on implementation and operation of the Pillar Two rules. Notification/Filing: The notification and filing requirements will be set out in the Executive Regulations. |
Romania | Law No. 431/2023 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups | Overview: Law No. 431/2023, which transposes the EU global minimum taxation directive into Romanian law, was published in Romania’s official gazette on 5 Jan 2024 and is effective as from 31 Dec 2023. The legislation includes an IIR and a UTPR and Romania has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Romanian resident entities on a consolidated basis. The IIR and QDMTT apply for fiscal years starting on or after 31 Dec 2023 and the UTPR applies for fiscal years starting on or after 31 Dec 2024. An ordinance that applies as from 1 Sept 2025 introduces marketable transferable tax credits and a carryforward mechanism for excess negative tax expense, updates the domestic top-up tax formula, clarifies the requirements for the QDMTT safe harbour, expands recognition of deferred taxes for non-IFRS filers and extends the notification filing deadline. Romania’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: Romania does not have a registration requirement, but a notification may be required and in-scope entities must file a GIR and a top-up tax return. If the GIR is not filed locally, the Romanian CE or designated local entity must file a notification disclosing the identity of the filing entity within 15 months from the end of the relevant fiscal year (18 months for the first year). Each CE in Romania must file a GIR, although if there are multiple Romanian CEs, a local entity may be designated to submit the GIR on behalf of the other Romanian CEs. A GIR is not required if one is filed by the UPE or a designated filing entity located in a jurisdiction that has concluded an automatic exchange of the annual GIR agreement with Romania for the reporting fiscal year. Each Romanian CE that is part of an in-scope MNE group is required to declare and pay its share of the domestic minimum top-up tax within 15 months of the end of the financial year (18 months for the first year), although the group can elect to designate a local CE to assume this responsibility. The tax authorities published the notification form on 11 Aug 2025 that is to be used to declare and pay the additional top-up tax. The notification form must be submitted within 12 months from the last day of the reporting year for the first year of application (extended from within six months). Designated software provided by the Romanian must be used to complete the form. The tax authorities held a consultation 7-17 Nov 2025 on proposed forms for making the notification and for filing the GIR, as well as draft instructions and a guide for completing the forms. |
Singapore | Multinational Enterprise (Minimum Tax) Act 2024 Multinational Enterprise
(Minimum Tax) Act 2024
(Declaration under Section 1(3)) Order 2024 | Overview: The Multinational Enterprise (Minimum Tax) Act and Income Tax (Amendment) Act were published in the government gazette on 27 Nov 2024. An order published by the Ministry of Finance on 31 Dec 2024 gives effect to the acts as from 1 Jan 2025. Regulations for the implementation of the global tax rules were published on the same date. The tax authorities released an e-tax guide on 31 Dec 2024 that sets out the key parameters of the taxes in the above acts and the subsidiary legislation. The legislation includes an MNE top-up tax (that applies the IIR) and a domestic top-up tax (DTT) as previously announced in the 2024 Budget Statement on 16 Feb 2024. A UTPR will be considered at a later stage. Parliament is looking at proposed amendments to Singapore’s Pillar Two rules (as part of the Finance (Income Taxes) Bill 2025, which received its first reading on 14 Oct 2025) that would introduce new technical definitions, revise administrative procedures and clarify the treatment of certain structures. Singapore’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: Singapore has a registration requirement and a notification of filing entity requirement. In-scope entities also must file a GIR and a top-up tax return. In-scope MNE groups must register with IRAS within six months after the end of the fiscal year. The group’s UPE must notify IRAS of the identity of the UPE, CEs, JVs and JV subsidiaries in Singapore, identities of excluded entities in the group, liability of the group, whether the GIR is to be filed outside Singapore, etc. The IRAS Comptroller can register the group in certain circumstances. A Singapore CE of a registered MNE group must be designated as the designated local filing entity of the group. If a designation is not made, the Comptroller may designate an entity. A notification of the filing entity must be submitted if the GIR is filed by the UPE or designated filing entity in another jurisdiction that has an information exchange agreement in effect with Singapore for the relevant year. The notification must be made within 15 months from the end of the relevant fiscal year (18 months for the first year of application). If an in-scope MNE group has multiple Singapore entities, one entity can be appointed as the designated local entity to submit the notification on behalf of all Singapore CEs. The designated filing entity must file a return stating whether or not IIR/DTT is payable and if it is, the amount. the group for the financial year or (ii) there is DTT payable with respect to the group and the amount of the IIR/DTT. The return must be filed within 15 months from the end of the relevant fiscal year (18 months for the first year of application) and tax paid within one month of filing the return. BDO insights https://www.bdo.com.sg/getmedia/0c1b36ec-d9bc-4f20-8fa8-7a9a1abc07d4/BDO-SG-Budget-Bulletin-2024.pdf https://www.bdo.global/en-gb/microsites/tax-newsletters/corporate-tax-news/issue-65-february-2023/singapore-budget-2023-measures-include-introduction-of-globe-rules-and-domestic-top-up-tax |
Slovak Republic | Law implementing the Directive on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union | Overview: Law 507/2023 of 8 Dec 2023, partly transposing the EU global minimum taxation directive into Slovak law, was published in the official gazette on 23 Dec 2023 and generally applies as from 31 Dec 2023. Amendments to the legislation were published on 17 Dec 2024, with the changes applying as from 31 Dec 2024. The law introduces a QDMTT to ensure a 15% minimum tax on Slovak resident CEs of in-scope MNE groups. The Slovak Republic has exercised the option under article 50(1) of the directive to delay application of the IIR and UTPR for six years until 2030. Article 50(1) allows EU member states with 12 or fewer UPEs of in-scope MNEs to delay the application of the rules. However, a member state that opts to make the election still must transpose all the other relevant directive measures to enable taxpayers and other EU member states and third countries to properly apply the system. Five member states—Estonia, Latvia, Lithuania, Malta and Slovakia—have exercised the election. A law published on 10 Nov 2025 incorporates the OECD guidance dating from 2024 and 2025 into Slovak law, amends the rules relating to deferred tax liability and includes rules for transparent entities and reverse hybrids with effect from 31 Dec 2025. The bill also includes transposes DAC9 into domestic law (DAC9 contains rules to facilitate the exchange of information relating to top-up tax returns). The bill still must be signed by the president and published before it can become effective. The Slovak Republic’s QDMTT is treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: The Ministry of Finance has published two notifications (Notification No. MF/15676/2025-724 and Compliance obligations are set out even though the Slovak Republic is deferring implementation of Pillar Two until 2030. The Slovak Republic’s implementing legislation does not address registration requirements. A Slovak CE entity must notify the tax authorities of the identity of the UPE or designated reporting entity by the deadline for submitting the information for determining the QDMTT. A Slovak CE entity also must submit information to the tax authorities that is needed to determine the QDMTT. If the MNE\a group has multiple Slovak constituent entities, a local entity can be designated to fulfill the reporting obligation on behalf of all CEs. This information must be submitted within 15 months after the last day of the reporting fiscal year (18 months for the first year). The Ministry of Finance has published two notifications (Notification No. MF/15676/2025-724 and Notification No. MF/15677/2025-724) on the issuance of a model tax return form for the QDMTT and instructions for completing the return. Each Slovak CE subject to the QDMTT must file a tax return and pay the top-up tax. The return and tax paid must be submitted within 15 months after the end of the relevant tax period (18 months for the first year of application). Other: On 12 Dec 2025, Estonia, Latvia, Lithuania, Malta and the Slovak Republic submitted a joint statement to the EU Finance Ministers requesting a review of the EU's implementation of the Pillar Two global minimum tax rules and specifically asked that the option to postpone application of the minimum tax be extended for an additional six years. BDO insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/european-union-five-eu-member-states-elect-to-delay-application-of-iir-and-utpr |
Slovenia | Minimum Tax Act | Overview: The legislation, the Minimum Tax Act, which transposes the EU global minimum taxation directive into domestic law, was published in the official gazette on 22 Dec 2023 and generally became effective on 1 Jan 2024. The legislation includes an IIR and a UTPR, and Slovenia has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Slovenian resident entities on a consolidated basis. The IIR and QDMTT apply for fiscal years starting on or after 31 Dec 2023 and the UTPR applies for fiscal years starting on or after 31 Dec 2024. Slovenia’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: There is no registration requirement in Slovenia, but a notification of the filing entity is required if the GIR is not filed locally. In addition, a GIR and top-up tax return must be filed. A CE in Slovenia or a designated filing entity must submit a GIR within 15 months after the end of the fiscal year in which the Pillar Two rules apply (18 months for the first fiscal year) unless the declaration was already submitted by the UPE or designated entity in its own jurisdiction. The declaration must include information on the identity of the CEs, the structure of the group (whether an MNE or large domestic group), as well as information needed to calculate the ETR. A Slovenian CE must file a top-up tax return electronically within the 30 days following the submission of the GIR. Amendments to the Tax Procedure Act published on 4 Dec 2025 include measures to introduce the Pillar Two information exchange provisions in DAC 9. (DAC9 contains rules to facilitate the exchange of information relating to top-up tax returns). |
South Africa | Minimum Tax Act | Overview: The Global Minimum Tax Act that implements a global minimum tax in South Africa was published on 24 Dec 2024. The act came into effect as from 1 Jan 2024 and applies to fiscal years starting on or after that date. On 12 Sept 2025, the tax authorities (South African Revenue Service or SARS) published an update on the implementation of the Pillar Two rules and announced that it is developing a portal for all GloBE-related information. The legislation includes an IIR and a domestic top-up tax (DTT) intended to be a QDMTT, but not a UTPR. The IIR applies to MNEs headquartered in South Africa that are within scope. The DTT applies where the ETR payable by an MNE in respect of its South African profits is lower than 15% and makes all South African CEs of such an MNE jointly and severally liable for topping up such tax to an ETR of 15%. The OECD safe harbours are adopted, and the administrative guidance released during 2023 is incorporated into the law. South Africa’s IIR and DMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: There is no registration requirement in South Africa, but there is a notification requirement. In-scope entities also must file a GIR and a top-up tax return. A domestic CE of an in-scope MNE group, domestic joint venture or domestic joint venture subsidiary of a domestic joint venture group must register and file a GIR with SARS in the prescribed form and format by the prescribed due date. If a designated local entity is appointed by one or more CEs required to file a GIR, the appointing CEs must notify SARS of the identity of the designated local entity that will file within six months before the GIR filing due date (15 or 18 months after the end of the reportable fiscal year for which the GIR must be filed). The first GIR must be filed within 18 months after the end of the first reportable fiscal year; the second and subsequent GIRs must be filed within 15 months after the end of the second and subsequent reportable fiscal years. SARS posted an update on its website on 30 Oct 2025 announcing that the launch of the GloBE notification and registration facilities on the SARS portal is being extended. The deadline for companies to notify the authorities of the entity that will submit the GIR is now 30 Apr 2026 and the deadline to submit the GIR is 30 Jun 2026. SARS is developing a portal to host all GloBE-related information. BDO Insights https://www.bdo.co.za/en-za/insights/2024/tax/globe-pillar-2-rules-to-be-implemented-in-south-africa |
Spain | Law 7/2024, of 20 December 2024, establishing a Complementary tax to ensure a global minimum level of taxation for multinational groups and large domestic groups | Overview : The Law 7/2024, of 20 December 2024, establishing a Complementary tax to ensure a global minimum level of taxation for multinational groups and large domestic groups was published in the official gazette on 21 Dec 2024 and applies retroactively to tax periods starting on or after 31 Dec 2023, transposing the EU global minimum taxation directive into Spanish law. The legislation is generally aligned with the EU Pillar Two Directive and includes some aspects of the OECD administrative guidance released in Apr 2024. The legislation includes an IIR and UTPR, and Spain has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Spanish resident entities on a consolidated basis. The IIR and QDMTT apply for tax years starting on or after 31 Dec 2023 and the UTPR generally applies as from 31 Dec 2024 (but it will not apply for tax years commencing before 31 Dec 2025 and ending before 31 Dec 2026 if the UPE is in a jurisdiction that has at least a 20% nominal corporate income tax rate). The legislation also contains a transitional CbCR safe harbour, a safe harbour for QDMTT and a transitional UTPR safe harbor. Regulations published on 2 Apr 2025 contain rules for calculating the tax base and adjusted covered taxes, filing the GIR and guidance on when the fiscal year of the UPE differs from that of the CEs. Spain’s IIR and DMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: Spain has a registration requirement but no notification of filing entity requirement. In-scope entities also must file a GIR and a top-up tax return. A Spanish CE is required to submit a “Communication Declaring the Complementary Tax Information Return” at least three months before the deadline for filing the GIR. The communication includes the start and end date of the tax period and the UPE or designated filing entity’s identity and country of residence. One communication can include the information for all Spanish CEs. Each Spanish CE must submit a GIR, although a GIR is not required in Spain if the return is filed by a UPE or designated filing entity in a jurisdiction that has a qualifying competent authority agreement in effect with Spain for the relevant year. A local entity may be designated as the filing entity if there are multiple CEs in Spain. The GIR must be filed within 15 months from the end of the relevant fiscal year (18 months for the first year of application). The GIR contains information about the group entities, group structure, ETR, top-up tax allocation and attribution, and other information needed to calculate the top-up tax. The top-up tax return must be file within 25 calendar days following the 15th month after the end of the relevant fiscal year (18th month for the first year of application). A Ministerial Order published on 29 Oct 2025 approves three tax forms, confirms the filing deadlines for the Pillar Two-related returns and notifications, and provides for the implementation of DAC9 into domestic law (i.e., rules to facilitate the exchange of information with respect to top-up tax information returns, etc.). The approved forms are: Form 240: Form 240 is used by a CE in Spain that is part of a covered MNE or domestic group to notify the Spanish tax authorities of the entity that will be filing the GIR. Form 240 must be submitted electronically at least three months before the deadline for filing the GIR, with an exception for fiscal years closing before 31 March 2025, in which case, Form 240 must be filed no earlier than 1 May and no later than 30 Jun 2026. Form 241: Form 240 is used for filing the GIR. A CE in Spain is required to electronically file the GIR by the last day of the 15th month following the relevant tax period (18th month for the first year) unless the GIR is filed by the UPE, the designated filing entity or a local filing entity. Form 242: Form 242 is the top-up tax self-assessment form. The form is to be used for filing the top-up tax return and must contain information relating to the reporting entity, the group (MNE group or domestic group), the UPE, the relevant tax period, etc. Form 242 must be filed electronically within 25 calendar days following the 15th month after the end of the relevant tax period (18th month for the first year). Other: The Basque Country published a law on 30 Apr 2025 that officially incorporates the Complementary Tax as a tax that can be regulated autonomously. On 11 Dec 2025, the European Commission announced that it has closed the infringement proceedings against Spain for failure to notify the Commission about measures transposing the EU global minimum taxation directive into its domestic law by the 31 Dec 2023 deadline. Infringement proceedings had been initiated against nine member states. BDO Insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/spain-government-approves-top-up-tax-returns |
Sweden | Act (2023:875) on additional tax | Overview: An amended version of the original bill that transposes the EU global minimum taxation directive into Swedish law was passed on 13 Dec 2023 and became effective on 1 Jan 2024. The Swedish tax authorities released guidance on the implementation of the rules on 20 Dec 2023. The legislation includes an IIR and a UTPR and Sweden has opted to adopt a QDMTT as provided in the directive to ensure a 15% minimum tax on Swedish resident entities on a consolidated basis. The IIR and the QDMTT apply for fiscal years starting on or after 31 Dec 2023 and the UTPR applies for fiscal years starting on or after 31 Dec 2024. Sweden’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Amending legislation—which applies as from 1 Jan 2025—incorporates the OECD administrative guidance from 2023 into Sweden’s rules, addresses artificial arrangements under the simplification rule and foreign currencies and potentially allows the offset of foreign additional tax in cases involving controlled foreign companies. Additional legislation (in Swedish only) published on 10 Dec 2025 incorporates OECD’s Jun 2024 administrative guidance. The Ministry of Finance (MOF) proposed legislation on 13 Nov 2025 that would implement DAC9 into Swedish law and amend the domestic Pillar Two rules to incorporate OECD administrative guidance, as well as measures relating to the GIR. Draft legislation released on 15 Aug 2025 would amend the Pillar Two rules to incorporate the OECD’s Jun 2024 guidance into the domestic measures, as well as guidance on how income and taxes are allocated between entities in cross-border structures and the treatment of deferred tax assets. Notification/Filing Sweden has a registration requirement and a notification of filing entity requirement. In-scope entities also must file a GIR and a top-up tax return. Swedish group entities that are part of an in-scope MNE group in Sweden must register with the Swedish Tax Agency within 15 months from the end of the tax year in which the registration requirement arose. A notification of the filing entity must be submitted if the GIR is filed by the UPE or designated filing entity in another jurisdiction that has an information exchange agreement in effect with Sweden for the relevant year. The notification must be made within 15 months from the end of the relevant fiscal year (18 months for the first year of application). If an in-scope MNE group has multiple Swedish entities, one entity can be appointed as the designated local entity to submit the notification on behalf of all Swedish CEs. Each Swedish CE must submit a GIR, although a GIR is not required in Sweden if the return is filed by a UPE or designated filing entity in a jurisdiction that has a qualifying competent authority agreement in effect with Sweden for the relevant year. A local entity may be designated as the filing entity if there are multiple CEs in Sweden. The GIR must be filed within 15 months from the end of the relevant fiscal year (18 months for the first year of application). The GIR contains information about the group entities, group structure, ETR, top-up tax allocation and attribution, and other information needed to calculate the top-up tax. A notification of the filing entity must be submitted if the GIR is filed by the UPE or designated filing entity in another jurisdiction that has an information exchange agreement in effect with Portugal for the relevant year. The notification must be made within 15 months from the end of the relevant fiscal year (18 months for the first year of application). If an in-scope MNE group has multiple Portuguese entities, one entity can be appointed as the designated local entity to submit the notification on behalf of all Portuguese CEs. A top-up tax return must be filed within one month after the deadline for filing the GIR and tax paid within 90 days from a notification by the tax authorities. |
Switzerland | Regulation on the minimum taxation of large corporate groups (in German only) | Overview: On 22 Dec 2023, the Federal Council enacted the ordinance that implements a supplementary tax that meets the standards for the Pillar Two QDMTT. The supplementary tax applies for fiscal years beginning on or after 1 Jan 2024. Initially, the Federal Council decided not to introduce an IIR or a UTPR. However, in a press release issued on 4 Sept 2024, the council announced that CEs will also be subject to a Swiss top-up tax under the IIR to complement the QDMTT for fiscal years starting on or after 1 Jan 2025. Switzerland’s IIR and QDMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. The Federal Tax Administration (FTA) released guidance on 24 Jul 2025, which clarifies that MNE businesses must take into account Swiss withholding taxes on distributions to owners when calculating QDMTT liability. However, any foreign taxes paid on such distributions are not considered covered taxes. Previous guidance issued on 18 Mar 2025 addresses the tax treatment of business units that qualify as PEs for purposes of the domestic minimum tax rules. The Federal Council held a public consultation from 29 Jan 2025 through 8 May on the basis under international law for enabling Switzerland to participate in the exchange of information under the global minimum tax; in-scope MNE would be able to submit the information centrally in a single jurisdiction. In a communication released 24 Jul 2025, the FTA clarified that section e of article 4.3.2 of the OECD’s GloBE rules (a rule on the allocation or reallocation of taxes on distributions) is not applicable to Switzerland’s QDMTT. Notification/Filing: Switzerland has a registration requirement but no notification of filing entity requirement. In-scope groups must submit a GIR and a top-up tax return. An in-scope CE must register in the central online portal (OMTax) within 15 months from the end of the relevant fiscal year (18 months for the first year of application). OMTax enables in-scope Swiss entities to electronically register for purposes of the Pillar Two rules and make their declarations. Registration is required before a GIR can be filed. A filing entity must be designated where an MNE group has more than one entity in Switzerland and the group will have to determine which entity will be the designated filing entity for purposes of the registration and filing process. This entity is usually the top domestic business entity or the most economically significant business entity. The designated entity must register in OMTax either directly or through a tax representative, and this must be completed before the tax return is filed, i.e., within 15 months after the end of the relevant tax year. The first Swiss QDMTT or IIR return, as well as the first GIR, are due within 18 months after the financial year-end, i.e., by 30 June 2026. The canton where the filing entity is located reviews the top-up tax declaration and is responsible for assessing and collecting the top-up tax. The government held a consultation in Apr 2025 on proposed amendments to the Pillar Two ordinance (in German only) that would add rules on how in-scope groups are to file their GIR returns and for the automatic exchange of the GIRs between the Swiss tax authorities and authorities in other jurisdictions. BDO insights https://www.bdo.ch/en-gb/insights/omtax_pillar-two-federal-tax-application-launched-in-switzerland https://www.bdo.global/en-gb/insights/tax/world-wide-tax/switzerland-global-minimum-tax-rate-now-in-effect https://www.bdo.global/en-gb/insights/tax/world-wide-tax/switzerland-pillar-two-implementation-approved-in-referendum |
Taiwan | | Overview: The government announced in Aug 2024 that it intends to revise the alternative minimum tax rules to bring the rate up to 15% from 12% for companies with global turnover exceeding EUR 750 million. The 12% would remain in effect for companies with global turnover below this threshold. In a press release issued 31 Aug 2023, the Ministry of Finance stated that even though Taiwan is not a member of the Inclusive Framework, Taiwan intends to implement a 15% global corporate minimum tax that is in line with the OECD Pillar Two standards, but the timeline is unclear. |
Thailand | Emergency Decree on Top-Up Tax B.E. 2567 (2024) of 26 December 2024 | Overview: An emergency decree that introduces Pillar Two rules were published in the official gazette on 26 Dec 2024 following cabinet approval on 11 Dec. The measures are generally in line with the OECD GloBE rules and include an IIR, a UTPR and a domestic minimum tax (DMTT). The decree applies as from 1 Jan 2025. The tax authorities likely will be proposing additional measures and implementation rules for the collection of the taxes. A draft bill provisionally approved by the cabinet on 3 Sept 2025 includes the introduction of qualified refundable tax credits under the minimum tax rules. The credits will be provided to promoted companies for investments or expenditures in areas such as R&D, advanced skills development, production efficiency improvement and sustainable investment, in an effort to enhance their competitiveness. The tax credits will be able to be used to deduct various tax payments or where promoted companies have remaining tax credits, to claim cash refunds. Thailand’s IIR and DMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: There is no registration requirement in Thailand, but in-scope entities must submit a notification, GIR and top-up tax return. A CE in Thailand must submit a notification form that includes information on the UPE and the designated CE responsible for filing the GIR (unless the CEs in Thailand appoint a designated filing entity to file the notification on their behalf). All CEs in Thailand must file a GIR and if there is more than one CE in Thailand, a local entity can be designated to file the return on behalf of all CEs. A GIR need not be filed if it is filed by the UPE or designated filing entity located in a jurisdiction that has a qualifying competent authority agreement in effect with Thailand for the relevant year. A Thai CE must file a top-up return. The registration, GIR and a Thai top-up tax return must be filed within 15 months after the end of the UPE’s accounting period, with payment of tax due at the same time. Payment of the tax must be in Thai currency. BDO insightshttps://www.bdo.global/en-gb/insights/tax/world-wide-tax/thailand-boi-relief-measures-granted-to-alleviate-the-impact-of-the-global-minimum-tax |
Turkey | Corporate Income Tax Law (as amended by Law No. 7524) | Overview: Türkiye has enacted legislation implementing the OECD Pillar Two global minimum tax and a domestic minimum tax. Law 7524, published in the official gazette on 2 Aug 2024, was presented to parliament on 15 Jul 2024 and approved on 28 Jul. The enacted measures include an IIR that applies to fiscal years starting from 1 Jan 2024, a UTPR that applies to fiscal years starting from 1 Jan 2025 and a QDMTT that applies to fiscal years starting from 1 Jan 2024. The legislation also includes safe harbours. A general communique that contains the implementing rules for the minimum tax have been presented to the president for signature and subsequent publication. The communiqué defines terms, outlines scope and exemptions, and provides guidance on calculating ETRs, determining covered taxes and filing information returns. It also incorporates the transitional safe harbour provisions so that no top-up tax will be due where an MNE group meets one of the following tests: (i) a de minimis test, under which jurisdictional revenue is under EUR 10 million and profit before tax is below EUR 1 million; (ii) a simplified ETR test, under which the jurisdictional ETR equals or exceeds 15% (2024), 16% (2025) or 17% (2026); or (iii) a routine profits test, under which jurisdictional profit equals or is less than the substance-based income exclusion amount. Türkiye’s IIR and DMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: There is no registration requirement in Turkey but there is a notification requirement, and in-scope entities must file a domestic top-up tax return, with the GIR as an annex to the return. A Turkish CE must file a top-up tax return and pay any top-up-tax resulting from IIR or UTPR by the last day of the 15th month following the close of the accounting period and, as noted above, include the GIR with the submitted documents. The DMTT must be declared and paid between the first and the last day of the 12th month following the end of the accounting year. However, on 1 Dec 2025, the authorities released a circular that extends the filing and payment deadlines for the DMTT; taxpayers may file the return and pay tax due by 15 Jan 2026 (rather than 31 Dec 2025). The Ministry of Treasury and Finance has power to determine the format and content of tax returns and any accompanying documents. BDO insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/turkey-global-minimum-tax-and-domestic-minimum-corporate-income-tax-introduced |
United Arab Emirates | Cabinet Decision 142 of 2024 | Overview: The Ministry of Finance announced on 6 Feb 2025 that a domestic minimum top-up tax (DMTT) on MNEs has been enacted and applies as from 1 Jan 2025 (Cabinet Decision 142 of 2024). Cabinet Decision 142 includes detailed provisions for the application of the DMTT in the UAE. This follows the MoF announcement on 9 Dec 2024 and Federal Decree Law No. 60 of 2023 that amended Federal Decree Law No 47 of 2022 (UAE corporate tax law) to incorporate the enabling provisions into the corporate tax framework. The Federal Tax Authority (FTA) has published an FAQ on its website. The UAE DMTT is in line with the OECD GloBE Model Rules and provides for necessary exclusions, safe harbours and transitional relief. It ensures that large MNEs with operations in the UAE are subject to a minimum ETR of 15% on their UAE profits. Ministerial Decision No. (88) of 2025 adopts all OECD administrative guidance on the GloBE rules issued up to Jan 2025. There is no IIR or UTPR. The Ministry of Finance announced on 16 Apr 2025 that a Ministerial decision published on 28 Mar 2025 adopts the full sets of OECD guidance and relevant commentary released up to Jan 2025. The guidance applies retroactively as from 1 Jan 2025. It is unclear how the DMTT will interact with free zone relief. The UAE’s DMTT is treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification/Filing: There is a registration requirement in the UAE but no notification requirement and in-scope entities must file a top-up tax return. Certain entities will be required to submit a Pillar Two information return to the FTA. In-scope entities are required to register with the Federal Tax Authority (FTA) in the form and manner set by the FTA and within prescribed deadlines. Any changes (e.g., the entity ceases to exist) also must be reported. These entities (or their domestic designated filing entity) are required to file a top-up tax return and discharge their top-up tax liability. BDO insights https://www.bdo.global/en-gb/insights/tax/world-wide-tax/united-arab-emirates-decoding-the-qdmtt-what-makes-a-domestic-minimum-top-up-tax-%E2%80%98qualified%E2%80%99-unde https://www.bdo.global/en-gb/insights/tax/world-wide-tax/united-arab-emirates-transitional-cbcr-safe-harbour-under-pillar-two-strategic-relief-or-complian https://www.bdo.global/en-gb/insights/tax/world-wide-tax/uae-oecd-guidance-on-global-anti-base-erosion-rules-adopted |
United Kingdom | Finance (No. 2) Act 2023 | Overview: The Pillar Two rules are included in Finance (No. 2) Act 2023 enacted on 11 Jul 2023. The UK measures follow the OECD GloBE model rules as closely as possible. The legislation, which applies for fiscal years starting on or after 31 Dec 2023, includes an IIR (referred to as the MTT or multinational top-up tax) and a QDMTT, but a UTPR was not adopted at the time. Finance Act 2025, which received Royal Assent on 21 Mar 2025, enacted a UTPR that applies for fiscal years starting on or after 31 Dec 2024 and introduced the transitional UTPR safe harbour and aspects of the OECD guidance from Dec 2023 and Jun 2024. The government issued the Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025 on 31 Mar 2025, which set out which jurisdictions have implemented a qualified income inclusion rule, a QDMTT and which QDMTTs qualify for the QDMTT safe harbour. The UK’s IIR and DMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. On 5 Aug 2025, HMRC (the UK tax authorities) published a comprehensive internal manual, the Multinational Top-up Tax and Domestic Top-up Tax manual, which sets out HMRC's position on issues relating to the top-up taxes following consultations. A policy paper and draft legislation released on 21 Jul 2025 contain amendments to Finance (No. 2) Act 2023 to align UK Pillar Two legislation with the OECD's Jan 2025 administrative guidance. On 15 Oct 2025, HMRC released an updated Notice 2 — Pillar Two top-up taxes relevant territories and taxes. Notification/Filing: In-scope MNE groups with at least one UK entity (or an in-scope UK standalone entity) must register with HMRC within six months of the end of the first accounting period that started on or after 31 Dec 2023 in which the group is subject to the rules, regardless of whether the group has a Pillar Two liability. The filing member can register on behalf of all group members. Any reporting-related changes must be made within six months of the change. HMRC released two sets of guidance on 1 Sept 2025: one on how to register to report Pillar Two taxes and one on how to report Pillar Two taxes . Registration for Pillar Two purposes is required if at least one entity is in the UK and has annual consolidated group revenue of EUR 750 million or more in at least two of the previous four accounting periods. A “filing member” (i.e., the UPE or a designated entity) must register within six months from the end of the first accounting period that started on or after 31 Dec 2023. Registered MNE groups must submit a tax return, regardless of whether the group has a domestic top-up tax liability. The return is due within 15 months from the end of the relevant accounting period (18 months for the first year) but not before 30 Jun 2026. HMRC has updated guidance on its website on How to prepare for the multinational top-up tax and the domestic top-up tax, which includes details of the reporting obligation relating to the MTT, the QDMTT and registration requirements and also addresses the transitional safe harbour rules and the election under these rules. Guidance released on 20 Nov 2024 set out how MNE groups should pay the domestic and multinational top-up taxes. BDO Insights: https://www.bdo.global/en-gb/insights/tax/world-wide-tax/united-kingdom-more-changes-proposed-to-pillar-two-rules https://bdoworld.sharepoint.com/sites/Tax/Lists/Editorial%20portal/DispForm.aspx?ID=471&e=Td5tpH https://www.bdo.co.uk/en-gb/microsites/budget-autumn-budget-2024 https://www.bdo.co.uk/en-gb/insights/tax/corporate-international-tax/pillar-two-how-it-will-work |
United States | | Overview: President Trump issued an Executive Order (EO) on 20 Jan 2025 declaring that the OECD global minimum corporate tax initiative “has no force or effect” in the US, effectively withdrawing the US from any participation in the global initiative. A memorandum released shortly after the EO directs the Treasury Department, in consultation with the United States Trade Representative, to investigate whether any foreign countries have tax rules in place or that are likely to be put in place that disproportionately affect American companies, and then to come up with options for “protective measures.” |
Uruguay | | Overview: The Budget Bill for 2025-2029 presented by the government on 31 Aug 2025 includes measures that would introduce a QDMTT designed to be in alignment with the Pillar Two GloBE rules and that would allow Uruguay to collect the top-up tax domestically. The QDMTT would apply to members of MNE groups with global revenue of at least EUR 750 million in two of the previous four years if the effective tax rate in Uruguay is below 15%. There are no plans to introduce an IIR or a UTPR. If enacted, the QDMTT would apply as from 2027. |
Vietnam | Resolution 107 (in Vietnamese only) | Overview: The resolution (Resolution 107) implementing the Pillar Two rules into Vietnamese law was adopted by the National Assembly on 30 Nov 2023, with the rules applying as from 1 Jan 2024. The resolution follows the Pillar Two model rules and contains an IIR and a QDMTT. There is no UTPR. A decree that became effective on 15 Oct 2025 and applies retroactively from fiscal year 2024 provides details on the application of the global minimum tax, in particular, which entities are covered and excluded, and notification/registration requirements. Vietnam’s IIR and DMTT are treated as “qualified” for GloBE purposes in the OECD’s Central Record of Legislation with Transitional Qualified Status. Notification / Filing: There is a registration and a notification requirement and two separate filing obligations in Vietnam, the top-up tax information return (GIR) and the regular tax return. MNE groups with CEs in Vietnam must register with the tax authorities within 90 days from the end of the UPE’s reporting fiscal year using a specific form. If an MNE group has more than one CE in Vietnam, the UPE or a CE in Vietnam must submit a notification to designate the filing CE within 30 days from the end of the reporting fiscal year using a specific form. The GIR must be submitted within 15 months after the end of the UPE's fiscal year (18 months for the 2024 year). The annual top-up return for entities subject to the IIR must be filed within 15 months after the end of the UPE's fiscal year (18 months for the 2024 fiscal year). |
Zimbabwe | Income Tax Act | Overview: Finance Act 2023, which was gazetted on 30 Dec 2023 and generally became effective on that date, includes provisions that introduce a 15% domestic minimum tax (DMTT) even though Zimbabwe is not a member of the Inclusive Framework. The Minister of Finance and Economic Development is authorised to issue implementing regulations. The DMTT is triggered when a foreign entity (the rules apply only to foreign entities) earns income from a business or an activity in Zimbabwe or when the foreign entity’s country of residence does not levy corporate tax or levies tax at an effective rate of less than 15%. Any shortfall below 15% must be paid as a top-up tax. A foreign entity for these purposes is an entity resident outside Zimbabwe, including a locally incorporated subsidiary or registered company of a foreign entity and a locally resident agent, arm or branch of a foreign entity. The Zimbabwe regime does not include a monetary threshold to fall within the scope of the rules but the national budget for 2026, presented on 27 Nov 2025, includes the adoption of a EUR 750 million minimum consolidated annual turnover threshold to facilitate the application of the DMTT provisions, as well as requirements for in-scope enterprises to furnish the Zimbabwe Revenue Authority with their groups’ consolidated annual turnover at the end of each year of assessment under the CbCR mechanism. The budget still must be approved and published before it is effective. |
