IIRs and DMTTs that don’t yet Qualify Under the OECD March 2025 Update

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 income inclusion rule (IIR) and domestic minimum tax (DMTT), including the QDMTT Safe Harbour. 

This was subsequently updated on March 31, 2025. 

The March 31, 2025 update approves transitional qualifying status for:

 – Guernsey: Qualifying IIR, Qualifying Domestic Minimum Top-Up Tax which also qualified for the QDMTT Safe Harbour

 – Spain: Qualifying IIR, Qualifying Domestic Minimum Top-Up Tax which also qualified for the QDMTT Safe Harbour

Jurisdictions that Qualify (and Don’t Qualify) Currently for Transitional Qualified Status

The table below indicates:

-which jurisdictions have an IIR or DMTT;

-the effective date of implementation;

-whether the IIR and DMTT qualify for Transitional Qualified Status;

-if there is a QDMTT, whether that qualifies for the QDMTT Safe Harbour (again under the Transitional Qualified Status rules).