August 28, 2025: Australia – On August 26, 2025, the Taxation (Multinational—Global and Domestic Minimum Tax) (Qualified GloBE Taxes) Determination 2025 was issued. This provides for a list of jurisdictions that have qualified status for the purposes of the income inclusion rule (IIR) and domestic minimum tax (DMTT), including the QDMTT Safe Harbour.
August 27, 2025: Australia- On August 27, 2025, the Australian Taxation Office issued a draft legislative instrument for consultation (the ‘Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR tax return and Australian DMT tax return) Determination 2025’). This outlines situations when entities within the scope of the Pillar 2 GloBE rules do not need to file an Australian DMT Return or an IIR/UTPR Return.
August 22, 2025: Romania – On August 20, 2025, the Romanian government issued a draft law for consultation. The law proposes amendments to various aspects of the Minimum Tax Act, including for the local accounting standard and local currency for QDMTT purposes, transferable tax credits and the excess negative tax carry forward election
August 21, 2025: Slovakia – On August 20, 2025, the Slovakian Government issued a draft law to implement the OECD June 2024 and January 2025 OECD Administrative Guidance.
August 20, 2025: Mauritius – The Finance Act 2025, enacted on August 8, 2025, includes a new QDMTT from July 1, 2025.
August 20, 2025: OECD – On August 18, 2025, the OECD updated the list of jurisdictions with Transitional Qualifying Status.
For all Pillar 2 Developments, see our Pillar Two Developments Tracker.
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On August 26, 2025, Australia issued a list of jurisdictions that have qualified status for the purposes of the income inclusion rule and domestic minimum
On August 27, 2025, the Australian Taxation Office issued a draft legislative instrument (the ‘Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR tax return
On August 20, 2025, the Romanian government issued a draft law for consultation. The law proposes amendments to various aspects of the Minimum Tax Act,
The Finance Act 2025, enacted on August 8, 2025, introduces a new Sub-Part AF to the Income Tax Act to include a domestic minimum top-up
On January 15, 2025, the OECD issued Administrative Guidance that includes a list of jurisdictions that have transitional qualified status for the purposes of the
On August 6, 2025, Germany issued the draft bill to amend the Minimum Tax Act. This follows the two previous discussion drafts and now includes
On March 20, 2025, the Swedish Ministry of Finance issued a proposal to amend the Global Minimum Tax Act. The final draft law was published
On August 13, 2025, Canada issued draft legislative proposals to amend its Global Minimum Tax Act to provide for aspects of the June 2024 and
Many jurisdictions will require GloBE registration for administrative purposes, however, the law issued to date has been inconsistent. We outline the GloBE registration obligations from
South Koreas 2025 Tax Reform Proposal (announced on July 31, 2025), provides that a QDMTT will be applied from January 1, 2026.
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