Full Steam Ahead For EU Pillar Two Implementation

The EU Council has reached agreement on the implementation of Pillar Two. On December 12, 2022, the EU issued a press release stating that ‘the ambassadors of EU member states decided to advise the Council to adopt the Pillar 2 directive, and a written procedure for the formal adoption will be launched.’

This is subject to a reservation from Poland which has asked for further time to consider the directive. 


On December 15, 2022, the Council of the European Union formally adopted (among other things) the EU Pillar Two directive. See: Poland Withdraws its Veto and the EU Pillar Two Directive is Adopted.

On December 22, 2022 the EU Global Minimum Tax Directive was published in the EU official journal as Council Directive (EU) 2022/2523 of 14 December 2022. Date of entry into force: 23 December 2022. 

EU member states  are required to enact laws, regulations and administrative provisions necessary to comply with the EU Pillar Two Directive by 31 December 2023.

The Income Inclusion Rule will apply in the EU for fiscal years beginning from  December 31, 2023 and the Under-Taxed Payments Rule will apply for fiscal years beginning from 31 December 2024.

Implementation in the EU will take Pillar Two towards the critical mass of countries required to reach the ‘tipping point’ for Pillar Two internationally.

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