Domestic GloBE Implementation

Last Updated: December 20, 2024

Note: For detailed information on the status of domestic legislation, including draft laws and other regulations, please see Pillar Two GloBE Legislation & Domestic Guidance

Members can access the latest 2024 Pillar 2 jurisdictional developments in our Pillar 2 Tracker. Earlier jurisdictional developments can be viewed at 2023 developments and 2022 developments.

Pillar Two Elections: Jurisdictional Matrix

Country	Status	IIR	UTPR	QDMTT	Analysis
African Tax Administration Forum (ATAF)	Draft Legislation	N/A	N/A	Yes	ATAF Releases Domestic Minimum Tax Legislation
Argentina	Planned for 2024 Budget package	Awaiting Details	Awaiting Details	Awaiting Details	See our Pillar Two Developments Tracker
Australia	Enacted Legislation (See our English Translation) See: Australia: GloBE Country Guide	January 1, 2024	January 1, 2025	January 1, 2024	Australia Enacts Pillar 2 Laws Australia Submits Pillar 2 Laws to Parliament A Review of Australia’s Draft Pillar Two Legislation Australia Issues Update on Global Minimum Tax Australian Budget Confirms 2024 GloBE Implementation Australia’s Consultation on Pillar Two See our Pillar Two Developments Tracker
Austria	Enacted Legislation (See our English Translation) See: Austria: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Austria Updates Minimum Tax Act for Aspects of OECD Administrative Guidance A Review of Austria’s Draft Pillar Two Law
Bahamas	Draft Legislation See: Bahamas: GloBE Country Guide	No	No	January 1, 2025 (unless the Group or any of its Constituent Entities is subject to an IIR or UTPR in another jurisdiction in respect of that Fiscal Year)	GloBE Country Guide: The Bahamas The Bahamas Issues a Policy Paper on a New CIT System, Including a QDMTT The Bahamas & Cayman Islands Approach To The Global Minimum tax See our Pillar Two Developments Tracker
Bahrain	Enacted Legislation (See our English Translation) See: Bahrain: GloBE Country Guide	No	No	January 1, 2025	Bahrain Issues Executive Regulations for the 2025 Domestic Top-Up Tax GloBE Country Guide: Bahrain
Barbados	Draft Legislation See: Barbados: GloBE Country Guide	No	No	January 1, 2024	GloBE Country Guide: Barbados Bermuda and Barbados Announce GloBE Implementation Barbados 2023 Budget Confirms Global Minimum Tax Proposals Are In Progress
Belgium	Enacted Legislation (See our English Translation) See: Belgium: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Belgium Issues a Draft 7 Page QDMTT Return for Consultation Belgium Extends Registration Deadline to September 16, 2024 if no 2024 GMT Advance Payments Belgian Royal Decree Sets July 13, 2024 as the Deadline for the First GloBE Notification Form Belgium’s Pillar Two Notification Form Requires Significant Data Input Belgium Issues Draft Law to Implement the OECD Administrative Guidance A Review of Belgium’s Draft Pillar Two Law
Bermuda	Enacted Legislation	No	No	No	Bermuda Issues Draft Corporate Income Tax Law Bermuda and Barbados Announce GloBE Implementation Bermuda Announces 2024 Global Minimum Tax in 2023 Throne Speech Bermuda Issues Consultation for a Corporate Income Tax Bermuda’s Plans For a Global Minimum Tax
Brazil	Enacted Law See: Brazil: GloBE Country Guide	No	No	January 1, 2025	Brazils Chamber of Deputies Ratifies Bill to Approve Provisional Measure No. 1,262/2024 to introduce a Domestic Minimum Tax Brazil Implements a QDMTT From January 1, 2025 Brazil Planning 15% Global Minimum Tax Implementation OECD Recommends Global Minimum Tax is Included in Brazil’s Tax Reform
British Virgin Islands (BVI)	Commentary	N/A	N/A	N/A	The BVI is Taking a Different Approach to the Bahamas for Pillar 2
Bulgaria	Enacted Legislation (See our English Translation) See: Bulgaria: GloBE Country Guide	January 1, 2024	January 1, 2025	January 1, 2024	Bulgaria’s GMT Amendment Act Sent to Parliament Bulgaria Issues a Draft Law to Provide for OECD Administrative Guidance, Including the UTPR Safe Harbour A Review of Bulgaria’s Draft Pillar Two Law
Canada	Enacted Legislation See: Canada: GloBE Country Guide	December 31, 2023	Draft Law (December 31, 2024)	December 31, 2023	Canada Issues Explanatory Notes on the Global Minimum Tax A Review of Canada’s Draft GloBE Law
Cayman Islands	Commentary	N/A	N/A	N/A	See our Pillar Two Developments Tracker
China	Commentary	N/A	N/A	N/A	Chinese Developments in Global Minimum Tax Implementation A Review of China’s Tax Law From a Pillar Two Perspective
Croatia	Enacted Legislation See: Croatia: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	See our Pillar Two Developments Tracker
Curacao	Draft Legislation	January 1, 2025	No	January 1, 2025
Cyprus	Draft Legislation (See our English Translation) See: Cyprus: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2024	Cyprus Parliament Approves Pillar 2 Law Cypriot GMT Law Tabled in Parliament Includes Detailed QDMTT Provisions Portugal Approves Pillar 2 Law, Bahamas and Cyprus Table Legislation in Parliament EU Gives Spain, Cyprus, Latvia, Lithuania, Poland and Portugal 2 Months to Enact Domestic Pillar 2 Laws EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2 A Review of Cyprus’s Draft Pillar Two Law
Czech Republic	Enacted Legislation (See our English Translation) See: Czech Republic: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Czech Republic Amends Draft Law Amending its GloBE Law A Review of the Czech Draft Top-Up Tax Act GloBE Country Guide: Czech Republic
Denmark	Enacted Legislation See: Denmark: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Denmark GloBE Country Guide: Updated for June 2024 Amending Law A Review of the Danish Draft Minimum Tax Act Danish Tax Authority Issues MNEs a Questionnaire for the GloBE Information Return
Estonia	Enacted Legislation See: Estonia: GloBE Country Guide	Art. 50 Postponement to December 31, 2029	Art. 50 Postponement to December 31, 2029	No	Estonia Issues Draft Pillar 2 Law Including Art. 50 Postponement EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2 See our Pillar Two Developments Tracker Pillar Two GloBE Rules and Estonia’s Distribution Tax
European Union	Enacted	December 31, 2023	December 31, 2024	Left to Individual EU Jurisdictions	EU Issues DAC 9 Proposal for Centralised GIR Filing Within the EU The New Zealand and EU Approaches to the Domestic Income Inclusion Rule (DIIR) EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2 EU Issues Commission Notice For Jurisdictions Delaying the IIR/UTPR Mapping the Model Rules to the EU Global Minimum Tax Directive Full Steam Ahead For EU Pillar Two Implementation Review of the Draft EU Pillar Two Directive
Finland	Enacted Legislation (See our English Translation) See: Finland: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Finland Issues Draft Pillar 2 Amendment Law to Reflect OECD Administrative Guidance Key Aspects of Finland’s Draft GloBE Law
France	Enacted Legislation (See our English Translation) See: France: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	France Issues a Decree for Pillar 2 Reporting Requirements France GloBE Country Guide Updated for the 2025 Finance Bill A Review of France’s Draft Pillar Two Law
Germany	Enacted Legislation (See our English Translation) See: Germany: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Germany Issues a Second Discussion Draft to Amend its GMT Law for June 2024 OECD Guidance German Annual Tax Act Includes GMT Amendments German MoF Issues Draft Law for AG3 Provisions Including Transitional CbCR and Blended CFC Rules Germany Releases its Group Parent Notification Form for German Minimum Tax Groups Germany Includes an Amendment to its GMT Law in the Draft Annual Tax Act Germany Issues Draft GMT Return For Feedback Germany Approves and Updates its GloBE Law Amendments to Germany’s Pillar 2 Regime in the Updated Draft Law GloBE Country Guide: Germany Germany Publishes Draft Global Minimum Tax Legislation German Proposals Include a Pillar Two Whitelist
Gibraltar	Draft Law See: Gibraltar: GloBE Country Guide	December 31, 2024	Awaiting Details	December 31, 2023	Gibraltar Issues Draft GloBE Law for a DMTT and IIR Gibraltar 2024 Budget Confirms QDMTT Introduction See our Pillar Two Developments Tracker
Greece	Enacted Legislation See: Greece: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Greece Enacts Pillar Two Law A Review of Greece’s Draft Pillar Two Law EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2 See our Pillar Two Developments Tracker
Guernsey	Enacted	January 1, 2025	No	January 1, 2025	Guernsey Enacts its Global Minimum Tax Law Guernsey, Jersey and the Isle of Man Announce a Global Minimum Tax From 2025
Hong Kong	Consultation/drafting legislation	January 1, 2025	Deferred to a later date	January 1, 2025	Hong Kong Issues Outcome of the Consultation on the Introduction of the GloBE Rules Hong Kong to Implement Global Minimum Tax in 2025 See our Pillar Two Developments Tracker
Hungary	Enacted Law (See our English Translation) See: Hungary: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Hungary GloBE Registration Form Available for Submission Hungary Issues GloBE Registration Form and Domestic Filing Entity Form GMT Amendments in the Hungarian Autumn Tax Package Passed to President for Signature Hungary Includes GloBE Amendments in its 2024 Autumn Tax Proposal Hungary Becomes The First EU Member To Enact Pillar 2 Law Hungary Approves and Updates its GloBE Law A Review of Hungary’s Draft Pillar Two Law Hungary’s Prime Minister Reiterates the Local Business Tax is a Covered Tax for GloBE Purposes
Iceland	Consultation	January 1, 2025	Awaiting Details	January 1, 2025	–
India	Commentary	Awaiting Details	Awaiting Details	Awaiting Details	India’s Tax Regime after Pillar Two: Key Risks and Opportunities
Indonesia	Partial Enactment + MoF statement	January 1, 2025	January 1, 2026	January 1, 2025	Indonesian Regulation Signals Global Minimum Tax Implementation Director of Indonesian Tax Authority Confirms Planned 2024 GloBE Implementation See our Pillar Two Developments Tracker
Ireland	Enacted Legislation See: Ireland: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Ireland’s 2024 Finance Act Includes Numerous GMT Adjustments for the OECD Administrative Guidance Ireland GloBE Country Guide Updated for the 2024 Finance Bill A Review of Ireland’s Draft Pillar Two Law Ireland Issues Second Feedback Statement on Pillar Two Ireland Issues Draft Global Minimum Tax Law For Feedback Irish 2022 Finance Bill Changes for Pillar Two
Isle of Man	Draft Law See: Isle of Man: GloBE Country Guide	January 1, 2025	No	January 1, 2025	Isle of Man Issues the Cessation Form for Pillar 2 Domestic Top-Up Tax Isle of Man Parliament Passes the Global Minimum Tax (Pillar Two) Order 2024 Isle of Man Issues Draft Legislation for the IIR and QDMTT from 2025 Isle of Man Announces QDMTT From 2025 Guernsey, Jersey and the Isle of Man Announce a Global Minimum Tax From 2025
Israel	Announcement	No	No	January 1, 2026	Israel to Apply a QDMTT from 2026 Israel Reaffirms Pillar Two Implementation Key Risks for MNEs Operating in Israel after Pillar Two
Italy	Enacted Legislation (See our English Translation) See: Italy: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Italy Issues SBIE Decree to Implement the July 2023 and June 2024 OECD Administrative Guidance Detailed Analysis of the Italian QDMTT Implementing Decree Italy Issues a Decree for the Transitional CbCR & UTPR Safe Harbours A Review of Italy’s Draft Pillar Two Law
Jamaica	Proposal	No	No	Awaiting Details (Planned Transposition from the OECD Model Rules)	See our Pillar Two Developments Tracker
Japan	Enacted Law (See our English Translation) See: Japan: GloBE Country Guide	April 1, 2024	No	Being Considered for 2025	Japan Issues Circular for Additional GloBE Guidance What Japan’s Cabinet Order on Pillar 2 Includes & Doesn’t Include Overview of Japan’s Latest Ministerial Ordinance on Pillar 2 GloBE Country Guide: Japan Overview of Japan’s Cabinet Order on the Global Minimum Tax Japan’s Global Minimum Tax Law Is Enacted See our Pillar Two Developments Tracker Japans Pillar 2 Proposals in its 2023 Tax Reform Outline Japan Submits Draft Pillar Two Law to Parliament Japan’s Accounting Standards Board Publishes Deferred Tax Guidance For Global Minimum Tax Sourcing the Japanese Pillar Two Law to the OECD Model Rules
Jersey	Enacted Law See: Jersey: GloBE Country Guide	January 1, 2025	No	No	Jersey GloBE Guide Updated for Final Enacted Law Jersey to implement an IIR and DMT from January 1, 2025 Guernsey, Jersey and the Isle of Man Announce a Global Minimum Tax From 2025 Jerseys approach to Pillar Two implementation
Kenya	Enacted Law	No	No	DMT – January 1, 2025	Kenya Enacts a Domestic Minimum Tax in its Tax Laws (Amendment) Act, 2024 Kenya Includes a Domestic Minimum Tax in its 2024 Finance Bill See our Pillar Two Developments Tracker
Kuwait	Draft Legislation (See our English Translation and our Kuwait: GloBE Country Guide)	No	No	January 1, 2025	Kuwait Issues a Draft Law to Introduce a Domestic To-Up Tax from 2025 Kuwait Considers Pillar Two Application IMF Recommends Extension of Kuwait’s CIT For GloBE Implementation
Latvia	Enacted Legislation See: Latvia: GloBE Country Guide	Art. 50 Postponement to December 31, 2029	Art. 50 Postponement to December 31, 2029	No	Latvian Parliament Adopts Law to Implement EU Minimum Tax Directive EU Gives Spain, Cyprus, Latvia, Lithuania, Poland and Portugal 2 Months to Enact Domestic Pillar 2 Laws Latvia Issues Draft Pillar Two Law & Confirms Postponement EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2
Liechtenstein	Enacted Legislation (See our English Translation) See: Liechtenstein: GloBE Country Guide	January 1, 2024	January 1, 2025	January 1, 2024	A Review of the Liechtenstein GloBE Regulation Liechtenstein Publishes Draft Global Minimum Tax Law
Lithuania	Enacted Legislation (See our English Translation) See: Lithuania: GloBE Country Guide	Art. 50 Postponement to December 31, 2029 (draft law to apply an IIR from January 1, 2025)	Art. 50 Postponement to December 31, 2029 (draft law to apply a UTPR from January 1, 2025)	No (draft law to apply a QDMTT from January 1, 2025)	Lithuania GloBE Country Guide Updated for Latest Draft Law EU Gives Spain, Cyprus, Latvia, Lithuania, Poland and Portugal 2 Months to Enact Domestic Pillar 2 Laws EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2 Lithuania Issues Draft Pillar Two Law & Confirms Postponement
Luxembourg	Enacted Legislation (See our English Translation) See: Luxembourg: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Luxembourg Parliament Approves Global Minimum Tax Amendment Law for OECD Administrative Guidance Luxembourg GloBE Guide Updated for October 2024 Amendments to Draft Law Luxembourg Government Approves Draft Law to Include Additional OECD Administrative Guidance Luxembourg Updates its Draft GloBE Law for OECD Administrative Guidance Key Aspects of the Luxembourg Draft GloBE Law Luxembourg Government Approves Pillar Two Bill Luxembourg Private Debt Funds and Pillar Two
Malaysia	Enacted Legislation See: Malaysia: GloBE Country Guide	January 1, 2025	No	January 1, 2025	Malaysia Issues Guidelines for the Implementation of the Global Minimum Tax GloBE Country Guide: Malaysia A Review of Malaysia’s Draft Pillar Two Law Malaysia’s 2024 Budget Proposes GloBE Implementation from 2025 Today’s Malaysian 2023 Revised Budget Stands by 2024 Global Minimum Tax Malaysia to Implement Global Minimum Tax & QDMTT in 2024
Malta	Enacted Legislation See: Malta: GloBE Country Guide	Art. 50 Postponement to December 31, 2029	Art. 50 Postponement to December 31, 2029	No	Malta Enacts EU Minimum Tax Directive With Art. 50 Postponement EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2 See our Pillar Two Developments Tracker
Mauritius	Partial Enactment	No	No	Included in Finance Act – Awaiting Details	Mauritius 2022 Finance Act includes Pillar Two Top-Up Tax
Mexico	Working Group	Awaiting Details	Awaiting Details	Awaiting Details	See our Pillar Two Developments Tracker
New Zealand	Enacted Legislation See: New Zealand: GloBE Country Guide	January 1, 2025	January 1, 2025	No (But a domestic IIR from January 1, 2026)	The New Zealand and EU Approaches to the Domestic Income Inclusion Rule (DIIR) New Zealand Updates Draft Global Minimum Tax Law & Delays Domestic IIR to 2026 New Zealand Issues Draft Global Minimum Tax Law New Zealand’s Approach to Pillar Two Direct Transposition of the GloBE Rules: Different Approaches By Switzerland & New Zealand
Nigeria	Rejected	No	No	No	Nigeria Reconsidering Its Approach To Pillar Two The Impact of Nigeria’s Rejection of Both Pillar 1 and 2
Norway	Enacted Law (See our English Translation) See: Norway: GloBE Country Guide	January 1, 2024	No (proposed in 2024 Budget to apply from 2025)	January 1, 2024	Norway GloBE Guide Updated for Amended Regulations Norway Sends its Updated GloBE Law to Parliament Norway Issues Consultation and Draft Law For Pillar 2 Rules
Oman	Commentary	Awaiting Details	Awaiting Details	Awaiting Details	Oman’s Tax Regime and Pillar Two
Paraguay	Working Group	Awaiting Details	Awaiting Details	Awaiting Details	See our Pillar Two Developments Tracker Paraguay’s Significant Pillar Two Risk
Philippines	Commentary	Awaiting Details	Awaiting Details	Awaiting Details	The Philippines Tax Regime and the Pillar Two GloBE Rules
Poland	Enacted Law See: Poland: GloBE Country Guide	January 1, 2025 (option to apply from January 1, 2024)	January 1, 2025	January 1, 2025 (option to apply from January 1, 2024)	Poland Enacts its Global Minimum Tax Law GloBE Country Guide: Poland Poland to Delay Pillar Two Implementation to 2025 EU Gives Spain, Cyprus, Latvia, Lithuania, Poland and Portugal 2 Months to Enact Domestic Pillar 2 Laws EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2 Delays in Poland’s Domestic Legislation
Portugal	Enacted Legislation See: Portugal: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	GloBE Country Guide: Portugal EU Gives Spain, Cyprus, Latvia, Lithuania, Poland and Portugal 2 Months to Enact Domestic Pillar 2 Laws EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2
Puerto Rico	Consultation	–	–	–
Qatar	Draft Law	Awaiting Details	Awaiting Details	Awaiting Details	See our Pillar Two Developments Tracker
Romania	Enacted Legislation (See our English Translation) See: Romania: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	GloBE Country Guide: Romania A Review of Romania’s Draft Pillar Two Law
Singapore	Enacted Legislation See: Singapore: GloBE Country Guide	January 1, 2025	No	January 1, 2025	Singapore Global Minimum Tax Law has been Published in the Official Gazette Singapore Global Minimum Tax Law has been Published in the Official Gazette Singapore Issues Draft Legislation for OECD Safe Harbours Singapore Introduces its Draft GloBE Law to Parliament Singapore To Implement Pillar Two From 2025 A Pillar Two Review of Singapore’s Tax System
Slovakia	Enacted Legislation (See our English Translation) See: Slovakia: GloBE Country Guide	Art. 50 Postponement to December 31, 2029	Art. 50 Postponement to December 31, 2029	December 31, 2023	Slovakian Parliament Approves the GMT Amendment Law Slovakia’s GloBE Law Applies the EU’s IIR/UTPR Postponement Provision See our Pillar Two Developments Tracker Slovakia Issues Draft Pillar Two Law
Slovenia	Enacted Legislation See: Slovenia: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	GloBE Country Guide: Slovenia
South Africa	Draft Legislation See: South Africa: GloBE Country Guide	January 1, 2024	No	January 1, 2024	South Africa Country Guide Updated for Latest Draft Laws GloBE Country Guide: South Africa South Africa Issues a Draft Law to Transpose the OECD GloBE Rules & Adopts an ‘Ambulatory’ Approach South Africa Issues Draft Global Minimum Tax Bill South Africa Confirms Global Minimum Tax In 2024 Taxation Laws Amendment Bill
South Korea	Enacted Law (See our English Translation) See: South Korea: GloBE Country Guide	January 1, 2024	January 1, 2025	No	A Review of South Korea’s Pillar Two Amendments to its Enforcement Regulation South Korea Releases Pillar Two Forms, Including GloBE Information Return & GloBE Tax Return A Review of South Korea’s Latest GloBE Amendments South Korea Issues Draft Pillar 2 Amendment Law Sourcing the South Korean Pillar Two Law to the OECD Model Rules GloBE Country Guide: South Korea First Domestic Pillar Two Global Minimum Tax Law Enacted Analysis of South Korea’s Draft Pillar Two Law English Translation of the South Korean Pillar Two Law The South Korean PE Risk Under Pillar Two
Spain	Draft Legislation (See our English Translation) See: Spain: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Spanish Parliament Publishes Draft GMT Law EU Gives Spain, Cyprus, Latvia, Lithuania, Poland and Portugal 2 Months to Enact Domestic Pillar 2 Laws EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2 Spain Issues Draft Pillar Two Legislation Spain Opens a Consultation on the Global Minimum Tax
Sweden	Enacted Legislation (See our English Translation) See: Sweden: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Sweden Issues Proposed Draft Legislation to Implement OECD Administrative Guidance GloBE Country Guide: Sweden Review of the Draft Swedish Global Minimum Tax Law English Translation of the Swedish Draft Global Minimum Tax Law
Switzerland	Enacted Legislation & Constitutional Amendment (See our English Translation) See: Switzerland: GloBE Country Guide	January 1, 2025	No	January 1, 2024	Swiss Federal Council Issues Amended Minimum Tax Ordinance for the IIR GloBE Country Guide: Switzerland Switzerland Applies IIR From January 1, 2025 Switzerland Issues Report on Cantonal Pillar 2 Developments Swiss Referendum Approves 2024 Global Minimum Tax Switzerland Issues Second Consultation on the GloBE Rules GloBE Country Guide: Switzerland Analysis of Switzerland’s Draft Pillar Two Decree Switzerland Approves the GloBE Rules Direct Transposition of the GloBE Rules: Different Approaches By Switzerland & New Zealand
Taiwan	No Legislative Schedule Provided	Awaiting Details	Awaiting Details	Awaiting Details	Taiwan’s Ministry of Finance Confirms No Timeline for Pillar 2 Implementation A Pillar Two Review of Taiwan’s Tax Regime Taiwan To Increase Its Domestic Minimum Tax Rate From 2024
Thailand	Draft Legislation See: Thailand: GloBE Country Guide	January 1, 2025	January 1, 2025	January 1, 2025	GloBE Country Guide: Thailand Thai Cabinet Approves Global Minimum Tax Proposal Thailand’s Tax Incentive Regime and Pillar Two
The Netherlands	Enacted Legislation (See our English Translation) See: The Netherlands: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	The Netherlands Parliament Approves Law to Amend its Global Minimum Tax Law for OECD Administrative Guidance The Netherlands Issues GloBE Amendments for OECD Administrative Guidance The Netherlands Sends GloBE Minimum Tax Act to Parliament GloBE Country Guide: The Netherlands Key Takeaways From the Dutch Draft Pillar Two Legislation
Turkey	Enacted Legislation See: Turkey: GloBE Country Guide	January 1, 2024	January 1, 2025	January 1, 2024	Turkey Gazettes Pillar 2 IASB Amendments
UAE	Announcement, Consultation + High Level Amendments to CIT Law	No	No	January 1, 2025	A Review of the UAE Consultation on the Introduction of the GloBE Rules See our Pillar Two Developments Tracker UAEs New Corporate Tax Law and Pillar Two
United Kingdom	IIR/QDMTT: Enacted Law UTPR: Proposed in the 2024-2025 Finance Bill See: The UK: GloBE Country Guide	31 December 2023	31 December 2024 (confirmed in the 2024-2025 Finance Bill)	31 December 2023	Review of the Pillar 2 Provisions in the UK Finance Bill 2024-2025 UK Issues Further Draft Pillar 2 Guidance UK to Apply Transitional CbCR Safe Harbour Anti-Avoidance Rule From March 14, 2024 UK Enacts 2024 Finance Act to Implement the OECD Administrative Guidance Review of the UK Draft UTPR Law UK Enacts New Multinational Top-Up Tax From December 31, 2023 UK Issues First Tranche of Draft Guidance on Global Minimum Tax Key Differences in Excluded Entities Between OECD Model Rules & UK Draft Legislation Review of the UK Global Minimum Tax in Yesterday’s 2023 Spring Finance Bill GloBE Country Guide: The United Kingdom UK Confirms 2024 Global Minimum Tax & QDMTT in 2023 Spring Budget A Review of the UK Draft Pillar Two Legislation UK Pushes Forward With Pillar Two UK Proposes Amendments to Global Minimum Tax Rules A Review of the UK QDMTT and the OECD Administrative Guidance
United States	Commentary	No	No	No	U.S Updates its GloBE Impact Document See our Pillar Two Developments Tracker
Vietnam	Resolution Enacted See: Vietnam: GloBE Country Guide	January 1, 2024	No	January 1, 2024	Vietnam Issues a Draft Decree for Detailed GloBE Provisions Vietnam Issues a Draft Decree for Detailed GloBE Provisions See our Pillar Two Developments Tracker Vietnam Issues Draft Pillar 2 Resolution Vietnamese Government Issues Resolution To Speed-Up Global Minimum Tax The Thorny Issue of Pillar Two in Vietnam Chairman of the Vietnamese National Assembly Confirms Pillar 2 Implementation Is Progressing
Zimbabwe	Legislation enacted	No	No	Domestic minimum tax

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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Luxembourg Parliament Approves Global Minimum Tax Amendment Law for OECD Administrative Guidance

Isle of Man Issues the Cessation Form for Pillar 2 Domestic Top-Up Tax

Kenya Enacts a Domestic Minimum Tax in its Tax Laws (Amendment) Act, 2024

The Netherlands Parliament Approves Law to Amend its Global Minimum Tax Law for OECD Administrative Guidance

Domestic GloBE Implementation

Note: For detailed information on the status of domestic legislation, including draft laws and other regulations, please see Pillar Two GloBE Legislation & Domestic Guidance

Members can access the latest 2024 Pillar 2 jurisdictional developments in our Pillar 2 Tracker. Earlier jurisdictional developments can be viewed at 2023 developments and 2022 developments.

Lee Hadnum