For all jurisdictional developments, including non-legislative proposals and consultations, see Domestic GloBE Implementation.
Country | GloBE Country Guide | Legislation | IIR | UTPR | QDMTT | Safe Harbours | Analysis |
United Kingdom | United Kingdom: GloBE Country Guide | Finance (No. 2) Bill for the ‘Multinational Top-Up Tax‘ in March 2023. | Yes (Accounting periods beginning on or after December 31, 2023) | No | Yes – Included in 2023 Spring Finance Bill | Yes – CbCR Safe Harbour | Review of the UK Global Minimum Tax in Yesterday’s 2023 Spring Finance Bill |
South Korea | South Korea: GloBE Country Guide | Law 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) | No | No | First 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 |
Mauritius | – | The 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 Details | Awaiting Details | Awaiting Details | Awaiting Details | Mauritius 2022 Finance Act includes Pillar Two Top-Up Tax |
Switzerland | Switzerland: GloBE Country Guide | On 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 Guidance | Switzerland Issues Second Consultation on the GloBE Rules Analysis of Switzerlands Draft Pillar Two Decree |
EU | – | 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. | Yes (Accounting periods beginning from December 31, 2023) | Yes (Accounting periods beginning from December 31, 2024) | Optional for Member States | Applies OECD Safe Harbours Guidance | Review of the Draft EU Pillar Two Directive Full Steam Ahead For EU Pillar Two Implementation |
The Netherlands | Netherlands: 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) | No | Key Takeaways From the Dutch Draft Pillar Two Legislation |
Indonesia | – | On 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 Regulations | Awaiting Regulations | Awaiting Regulations | Awaiting Regulations | Indonesian Regulation Signals Global Minimum Tax Implementation |
Sweden | Sweden: GloBE Country Guide | On 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)) | No | See our Review of the Draft Swedish Global Minimum Tax Law |
Japan | Japan: GloBE Country Guide | On 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) | No | No | High Level Transitional CbCR Safe Harbour | Japan’s Global Minimum Tax Law Is Enacted |
Germany | Germany: GloBE Country Guide | On 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 |
Liechtenstein | Liechtenstein: GloBE Country Guide | On 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 Relief | Liechtenstein Publishes Draft Global Minimum Tax Law |
Ireland | Ireland: GloBE Country Guide | On 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 law | Yes but no details in draft law | Ireland Issues Draft Global Minimum Tax Law For Feedback |
New Zealand | New Zealand: GloBE Country Guide | On 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. | Yes | Yes | No | Yes | New Zealand Issues Draft Global Minimum Tax Law |
Cookie | Duration | Description |
---|---|---|
cookielawinfo-checkbox-analytics | 11 months | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics". |
cookielawinfo-checkbox-functional | 11 months | The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional". |
cookielawinfo-checkbox-necessary | 11 months | This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary". |
cookielawinfo-checkbox-others | 11 months | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other. |
cookielawinfo-checkbox-performance | 11 months | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance". |
viewed_cookie_policy | 11 months | The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data. |