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GloBE Country Guides: Summary

Country-Specific Analysis of Legislation to Implement the Pillar Two GloBE Rules

Summary: Current Legislation (Draft or Enacted)

For all jurisdictional developments, including non-legislative proposals and consultations, see Domestic GloBE Implementation.

Country GloBE Country GuideLegislationIIRUTPRQDMTTSafe HarboursAnalysis
United KingdomUnited Kingdom: GloBE Country GuideFinance (No. 2) Bill for the ‘Multinational Top-Up Tax‘ in March 2023. Yes (Accounting periods beginning on or after December 31, 2023)NoYes – Included in 2023 Spring Finance BillYes – CbCR Safe HarbourReview of the UK Global Minimum Tax in Yesterday’s 2023 Spring Finance Bill
South KoreaSouth Korea: GloBE Country GuideLaw 19191 to amend the International Tax Adjustment Act to provide for the Pillar Two Global Minimum Tax from January 1, 2024. Yes (Accounting Periods beginning on or after January 1, 2024)Yes (Accounting Periods beginning on or after January 1, 2024)NoNoFirst Domestic Pillar Two Global Minimum Tax Law Enacted

Analysis of South Korea’s Draft Pillar Two Law

English Translation of South Korean Pillar Two Law
MauritiusThe Finance (Miscellaneous Provisions) Act 2022 which implements provisions of the 2022 Budget in Mauritius includes mention of a qualified domestic minimum tax for Pillar Two purposes. Awaiting DetailsAwaiting DetailsAwaiting DetailsAwaiting DetailsMauritius 2022 Finance Act includes Pillar Two Top-Up Tax
SwitzerlandSwitzerland: GloBE Country GuideOn August 17, 2022, the Swiss Federal Council issued a draft decree for the implementation of Pillar Two.

On May 24, 2023, Switzerland issued an updated Draft Decree for the Pillar Two Global Minimum Tax.
Yes (Accounting Periods beginning on or after January 1, 2024)Yes (Accounting Periods beginning on or after January 1, 2025)Yes (Accounting Periods beginning on or after January 1, 2024))Transposed from OECD GuidanceSwitzerland Issues Second Consultation on the GloBE Rules

Analysis of Switzerlands Draft Pillar Two Decree
EUOn 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.Yes (Accounting periods beginning from December 31, 2023)Yes (Accounting periods beginning from December 31, 2024)Optional for Member StatesApplies OECD Safe Harbours GuidanceReview of the Draft EU Pillar Two Directive

Full Steam Ahead For EU Pillar Two Implementation
The NetherlandsNetherlands: GloBE Country Guide The Netherlands Published draft legislation for Pillar Two on October 24, 2022.Yes (Accounting periods beginning from December 31, 2023)Yes (Accounting periods beginning from December 31, 2024)Yes (Accounting periods beginning from December 31, 2023)NoKey Takeaways From the Dutch Draft Pillar Two Legislation
IndonesiaOn December 20, 2022, Indonesia issued Government Regulation No. 55/2022 on the Adjustment of Regulations in the Field of Income Tax. This included reference to the implementation of a global minimum tax in Indonesia as well a a desire to implement Pillar One.Awaiting RegulationsAwaiting RegulationsAwaiting RegulationsAwaiting RegulationsIndonesian Regulation Signals Global Minimum Tax Implementation
SwedenSweden: GloBE Country GuideOn February 7, 2023, the Special Investigator submitted the Interim Report on the proposal for the implementation of the Global Minimum Tax Directive to the government. This includes outline draft legislation.Yes (Accounting periods beginning after December 31, 2023)Yes (Accounting periods beginning after December 31, 2024)Yes (Yes (Accounting periods beginning after December 31, 2023))NoSee our Review of the Draft Swedish Global Minimum Tax Law
JapanJapan: GloBE Country GuideOn March 28, 2023, Japan enacted a domestic law to give effect to the Pillar Two GloBE rules.

On February 3 and 6, 2023, the Ministry of Finance published the “Bill for the Partial Revision of the Income Tax Act”. This includes the implementation of the Pillar Two GloBE rules.
Yes Accounting Periods beginning on or after April 1, 2024)NoNoHigh Level Transitional CbCR Safe HarbourJapan’s Global Minimum Tax Law Is Enacted
GermanyGermany: GloBE Country GuideOn March 20, 2023, the German Federal Ministry of Finance published a consultation, including a draft law (the Minimum Taxation Directive Implementation Act), to implement the EU Global Minimum Tax Directive. Yes (Accounting Periods beginning after December 30, 2023)Yes (Accounting Periods beginning after December 30, 2024)Yes (Accounting Periods beginning after December 30, 2023)Yes (CbCR Safe Harbour, Simplified Calculation Safe Harbour & the QDMTT Safe Harbour)Germany Publishes Draft Global Minimum Tax Legislation
LiechtensteinLiechtenstein: GloBE Country GuideOn March 29, 2023, Liechtenstein published draft legislation for the implementation of the Pillar Two Globe Rules.Yes (Accounting Periods beginning on or after January 1, 2024)Yes (Accounting Periods beginning on or after January 1, 2025)Yes (Accounting Periods beginning on or after January 1, 2024)Yes – CbCR Safe Harbour + Penalty ReliefLiechtenstein Publishes Draft Global Minimum Tax Law
Ireland Ireland: GloBE Country GuideOn March 31, 2023, the Irish government issued a Feedback Statement on the Pillar Two Global Minimum Tax.

It includes draft legislation and outlines possible draft legislative approaches to key elements of the GloBE Rules.
Yes (Accounting periods beginning on or after December 31, 2023)Yes (Accounting periods beginning on or after December 31, 2024)Yes but no details in draft lawYes but no details in draft lawIreland Issues Draft Global Minimum Tax Law For Feedback
New ZealandNew Zealand: GloBE Country GuideOn May 18, 2023, New Zealand published a draft law (the Taxation (Annual Rates for 2023–24, Multinational Tax, and Remedial Matters) Bill) to implement the Pillar Two Global Minimum Tax.YesYesNoYesNew Zealand Issues Draft Global Minimum Tax Law