Jurisdictions Members-Only

Estimated Critical Mass After Draft/Proposed Legislation Is Enacted

Map: Pillar Two Implementation

Country	Status	Implementation	QDMTT	Analysis
African Tax Administration Forum (ATAF)	Draft Legislation	N/A	Yes	ATAF Releases Draft Domestic Minimum Tax Legislation
Australia	Consultation	Expected 2024	Expressed Interest	Australia’s Consultation on Pillar Two
Bahamas	Working Group	N/A	Awaiting Details	The Bahamas & Cayman Islands Approach To The Global Minimum tax See our Pillar Two Developments Tracker
Belgium	Proposal	2024	Awaiting Details	See our Pillar Two Developments Tracker
Bermuda	Working Group	N/A	Awaiting Details	Bermuda’s Plans For a Global Minimum Tax
Brazil	Commentary	N/A	N/A	OECD Recommends Global Minimum Tax is Included in Brazil’s Tax Reform
British Virgin Islands (BVI)	Commentary	N/A	No	See The BVI is Taking a Different Approach to the Bahamas for Pillar 2
Canada	Awaiting Draft Legislation	Expected 2024	Expressed Interest	See our Pillar Two Developments Tracker
Cayman Islands	Commentary	N/A	No	See our Pillar Two Developments Tracker
China	Commentary	N/A	N/A	Chinese Developments in Global Minimum Tax Implementation A Review of China’s Tax Law From a Pillar Two Perspective
Estonia	Commentary	N/A	Awaiting Details	Pillar Two GloBE Rules and Estonia’s Distribution Tax
European Union	Enacted	2024	Left to Individual EU Jurisdictions	Full Steam Ahead For EU Pillar Two Implementation Review of the Draft EU Pillar Two Directive
Hong Kong	Proposal	2025	Planned for 2025	Hong Kong to Implement Global Minimum Tax in 2025 See our Pillar Two Developments Tracker
Hungary	Commentary	2024	Awaiting Details	Hungary’s Prime Minister Reiterates the Local Business Tax is a Covered Tax for GloBE Purposes
India	Commentary	N/A	N/A	India’s Tax Regime after Pillar Two: Key Risks and Opportunities
Indonesia	Partial Enactment	2024	Awaiting Details	Indonesian Regulation Signals Global Minimum Tax Implementation Director of Indonesian Tax Authority Confirms Planned 2024 GloBE Implementation See our Pillar Two Developments Tracker
Ireland	Consultation	2024	Awaiting Details	Irish 2022 Finance Bill Changes for Pillar Two
Israel	Commentary	Commentary	Awaiting Details	Key Risks for MNEs Operating in Israel after Pillar Two
Japan	Draft Law	April 2024	Being Considered for 2025	See our Pillar Two Developments Tracker, Japans Pillar 2 Proposals in its 2023 Tax Reform Outline Japan Submits Draft Pillar Two Law to Parliament
Jersey	Consultation/Awaiting Draft Legislation	Expected 2024	Expressed Interest	Jerseys approach to Pillar Two implementation
Liechtenstein	Awaiting Consultation in March 2023	2024	Awaiting Details	Liechtenstein to Consult on Pillar Two Global Minimum Tax
Luxembourg	Commentary	N/A	Awaiting Details	Luxembourg Private Debt Funds and Pillar Two
Malaysia	Proposal	2024	Planned for 2024	Today’s Malaysian 2023 Revised Budget Stands by 2024 Global Minimum Tax Malaysia to Implement Global Minimum Tax & QDMTT in 2024
Malta	Commentary	2030	Awaiting Details	See our Pillar Two Developments Tracker
Mauritius	Partial Enactment	N/A	Included in Finance Act – Awaiting Details	Mauritius 2022 Finance Act includes Pillar Two Top-Up Tax
Mexico	Working Group	2024	Awaiting Details	See our Pillar Two Developments Tracker
New Zealand	Awaiting Draft Legislation	N/A	Consultation was Non-Committal, therefore Awaiting Details	New Zealand’s Approach to Pillar Two
Nigeria	Rejected	N/A	N/A	The Impact of Nigeria’s Rejection of Both Pillar 1 and 2
Oman	Commentary	N/A	N/A	Oman’s Tax Regime and Pillar Two
Paraguay	Working Group	N/A	Awaiting Details	See our Pillar Two Developments Tracker Paraguay’s Significant Pillar Two Risk
Philippines	Commentary	N/A	N/A	The Philippines Tax Regime and the Pillar Two GloBE Rules
Qatar	Commentary	15%	Awaiting Details	See our Pillar Two Developments Tracker
Singapore	Proposal	2025	Planned for 2025	Singapore To Implement Pillar Two From 2025 A Pillar Two Review of Singapore’s Tax System
South Africa	Awaiting Consultation	2025	Awaiting Details	See South Africa Confirms Global Minimum Tax In 2024 Taxation Laws Amendment Bill
South Korea	Enacted	2024	No	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	Consultation	2024	Expressed Interest	Spain Opens a Consultation on the Global Minimum Tax
Sweden	Consultation/Draft Law	2024	Proposed	GloBE Country Guide: Sweden Review of the Draft Swedish Global Minimum Tax Law English Translation of the Swedish Draft Global Minimum Tax Law
Switzerland	Draft Law & Draft Constitutional Amendment	2024	Yes, Planned for 2024	GloBE Country Guide: Switzerland Analysis of Switzerland’s Draft Pillar Two Decree Switzerland Approves the GloBE Rules
Taiwan	Proposal/Commentary	2024	Awaiting Details	A Pillar Two Review of Taiwan’s Tax Regime Taiwan To Increase Its Domestic Minimum Tax Rate From 2024
Thailand	Proposal	2025	Expressed Interest	Thai Cabinet Approves Global Minimum Tax Proposal Thailand’s Tax Incentive Regime and Pillar Two
The Netherlands	Draft Legislation	2024	Yes, Planned for 2025	GloBE Country Guide: The Netherlands Key Takeaways From the Dutch Draft Pillar Two Legislation
UAE	Commentary	N/A	N/A	UAEs New Corporate Tax Law and Pillar Two
United Kingdom	Draft Legislation	2024	Yes – Not In Draft Legislation but included in Spring 2023 Budget	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
United States	Commentary	N/A	N/A	U.S Updates its GloBE Impact Document See our Pillar Two Developments Tracker
Vietnam	Working Group	N/A	Awaiting Details	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

Tools

Tools, Trackers & Maps Members-Only

Trackers

Pillar Two Developments Tracker Updated

Global Digital Service Tax Tracker Updated

Global VAT on Digital Services Tracker Updated

Maps

Global R&D Effective Tax Rate Map New

Interactive Global R&D Map Updated

STTR: Global WHT Map Updated

2022 Global Corporate Tax Rates Map

Modelling Tools

Pillar 1 & 2 Modelling Tool

Top-Up Tax Modelling Tool – Unlimited Companies

Pillar 2 Tax Engine

VAT on Digital Services: Global Assessment Tool New

Global IP Tax Incentives Tool New

Payroll Tax Incentives – Pillar Two Modelling Tool New

CFC Pushdown Limitation Tool

GloBE Loss Election – Interactive Tool

Transitional CbCR Safe Harbour Modelling Tool

Modelling Tools

Domestic Minimum Tax – Interactive Tool

Pillar Two Deferred Tax Recapture Tool

Pillar 2 Modelling Tool – OECD CbC Data New

Investment Company Top-Up Tax Tool

Rapid Assessment Tool

Deferred Tax Asset Calculator

UTPR Calculator

Income Inclusion Rule Calculator

Pillars Modelling Tools
MNE Systems

MNE Systems Members-Only

Pillar Two Report: MNE Systems Planning

122 Data Points for Pillar Two

UPE Data Points for the GloBE Return

Data Points for Pillar Two Corporate Structures

Data Points For the Transitional CbCR Safe Harbour

Benefits of a Pillar Two Impact Assessment

Decentralized Data Management for Pillar Two

Why MNEs Should Reassess SPVs

Deferred Tax Tracking

Roadmap for a Pillar Two Impact Assessment

Comprehensive Data Points for the Substance-Based Income Exclusion

Tax Data Mapping Assessment

Trending Now

GloBE Country Guide: Switzerland

UK Confirms 2024 Global Minimum Tax & QDMTT in 2023 Spring Budget

GloBE Country Guide: The United Kingdom

Summary

Status	Draft
Law	Draft Multinational Top-Up Tax Law of July 20, 2022.
Effective Date	Proposed January 1, 2024.
IIR	Yes (2024).
UTPR	No.
QDMTT	Yes – Included in 2023 Spring Budget proposal.
Filing Deadlines	Standard.

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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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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GloBE Country Guide: The United Kingdom

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Lee Hadnum