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QDMTT: Legislative Tracker

Many jurisdictions implementing Qualified Domestic Minimum Top-Up Taxes (QDMTTs) in order to protect their domestic tax revenue base.
 
The design of domestic QDMTTs is much more flexible than legislation to implement the GloBE Rules. The OECD Administrative Guidance (and in particular, the Second Set of Administrative Guidance issued on July 17, 2023) provides details on which aspects of the GloBE Rules need to be reflected in a domestic minimum tax regime and which aspects don’t in order for it to be a QDMTT.  The Fourth Set of OECD Administrative Guidance (issued on June 17, 2024) also includes additional amendments to the design of QDMTTs. 
 
In general, it is beneficial to adapt the design of the QDMTT to reflect the domestic tax regime as otherwise this could exacerbate the complexity of a QDMTT and include provisions that aren’t even relevant to the jurisdiction (eg the stock-based compensation election, that would not be relevant if the jurisdiction did not allow companies to deduct the value of stock-based compensation based on the market value of the stock.)
 
This therefore means there are likely to be significant global variations in the application of QDMTTs. Note that some design features of a QDMTT could prohibit the QDMTT Safe Harbour applying due to the consistency standard not being met. For more information, see QDMTT Safe Harbour.
 
In our QDMTT Legislative Tracker we analyse and compare QDMTT legislation that has been released to date to identify areas where different approaches are taken. 
 
QDMTT Legislative Tracker
QDMTT Tracker

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Lee Hadnum

Lee is a qualified Chartered Accountant and Chartered Tax Adviser. A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

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