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 and domestic minimum tax (including the QDMTT Safe Harbour). This was subsequently updated on March 31, 2025.
Belgium Issues its QDMTT Return
On April 10, 2025, the Belgium Ministry of Finance issued the QDMTT Return. This is still considered as draft until published in the Official Gazette but is unlikely to now change as this follows a consultation of a previous draft of the QDMTT Return that lasted until November 8, 2024.
Japan Enacts Law for QDMTT and UTPR from April 1, 2026
Om March 31, 2025, the Law to Partially Amend the Income Tax Act was published in the Official Gazette. This implements the UTPR and QDMTT from April 1, 2026.
Germany Issues Guidance on the Treatment of Tax Transparent Partnerships for the CbCR Safe Harbour
On April 3, 2025, the Federal Ministry of Finance issued a letter on the application of Country-by-Country (CbC) reporting for transparent partnerships, including the impact on the Transitional CbCR Safe Harbour for Pillar 2 purposes.
Finland Issues Guidance for the Application of the Global Minimum Tax
On March 10, 2025 and March 12, 2025, Finland issued explanatory guidance on the application of the Minimum Tax Act, including provisions from the OECD June 2024 Administrative Guidance relating to the DTL recapture.
Spain Issues Regulations for the Global Minimum Tax Act
On April 2, 2025, Spain issued Regulations for the application of the Global Minimum Tax Law. This includes a number of aspects of the OECD Administrative Guidance.
The Treatment of Permanent Establishments under Pillar Two
Permanent Establishments (PEs) are subject to a number of specific rules under Pillar Two in order to apply the general provisions to them. Key issues are what is a PE under Pillar Two? where is it located? and how are income and taxes allocated to it?
UK Issues a List of Jurisdictions that Have Qualified IIRs and DMTTs for Pillar 2
On March 21, 2025, the UK approved a list of jurisdictions that have qualified status for the purposes of the income inclusion rule and domestic minimum tax (including the QDMTT Safe Harbour).
GloBE Country Guide: Qatar
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Qatar for accounting periods beginning on or after January 1, 2025.
Qatar Enacts a Pillar Two Income Inclusion Rule and Domestic Minimum Tax
On March 27, 2025, Law No. 22 of 2024 was published in Qatar’s Official Gazette. This implements the Pillar Two Income Inclusion Rule and a Domestic Minimum Top- Up Tax from January 1, 2025.
