All GloBE Country Guides provide detailed guidance on the domestic implementation of the Pillar 2 GloBE rules in the specified jurisdiction. This includes:
-General Overview of the Domestic Law(s) Implementing Pillar 2;
-Specific Design Features;
-Implementation of the OECD Administrative Guidance;
-Implementation of the OECD Safe Harbours;
-Elections in the OECD Model Rules;
-Elections in the Administrative Guidance;
-Derivations from the OECD Model Rules/EU Global Minimum Tax Directive;
-QDMTT Design Features;
-Registration Obligations;
-Filing Requirements (both the GIR and domestic tax returns);
-Top-up Tax Payment Requirements; and
-Penalties.
For all jurisdictional developments, including non-legislative proposals and consultations, see Domestic GloBE Implementation.
| Country | GloBE Country Guide | Substantive Enactment for Tax Accounting? | Legislation | IIR | UTPR | QDMTT | Safe Harbours | Analysis |
| Australia | Australia: GloBE Country Guide | No (After approval of both Houses of Parliament) | On July 4, 2024, draft legislation was submitted to Parliament. This includes the Taxation (Multinational-Global and Domestic Minimum Tax) Bill 2024, Taxation (Multinational-Global and Domestic Minimum Tax) Imposition Bill 2024 and the Treasury Laws Amendment (Multinational-Global and Domestic Minimum Tax) (Consequential) Bill 2024. On March 21, 2024, the Australian Treasury released draft legislation and draft rules as part of a consultation to implement the Pillar Two GloBE Rules. This includes an IIR, UTPR and a domestic minimum tax. Explanatory notes were also issued. | 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 – Transitional CbCR Safe Harbour, QDMTT Safe Harbour and the Simplified calculation for Non-Material Constituent Entities Safe Harbour | A Review of Australia’s Draft Pillar Two Legislation |
| Austria | Austria: GloBE Country Guide | Yes | On December 30, 2023, the Austrian Federal Law Gazette No. 187/2023 published the Minimum Taxation Reform Act to implement the EU Minimum Tax Directive from January 1, 2024. On December 14, 2023, the Austrian National Council passed the Draft Pillar Two Law. On October 3, 2023, the Austrian Federal Ministry of Finance issued the ‘Federal law enacting the Federal Act to Ensure a Global Minimum Taxation for Groups of Companies’ to implement the Pillar Two GloBE rules/EU Minimum Tax Directive. | Yes (Accounting periods beginning on or after December 31, 2023) | Yes (Accounting periods beginning on or after December 31, 2024) | Yes (Accounting periods beginning on or after December 31, 2023) | Yes – Transitional CbCR Safe Harbour, QDMTT Safe Harbour, Transitional UTPR Safe Harbour; and the Simplified calculation for Non-Material Constituent Entities Safe Harbour | A Review of Austria’s Draft Pillar Two Law |
| Barbados | Barbaos: GloBE Country Guide | No | On February 28, 2024, the Corporation Top-up Tax Bill, 2024 received its first reading in the House of Assembly. | No | No | Yes (Accounting periods beginning on or after January 1, 2024) | Yes – Transitional CbCR Safe Harbour, | – |
| Belgium | Belgium: GloBE Country Guide | Yes | On May 12, 2024, the Belgian Official Gazette published a law which includes provisions to amend the ‘Act on the introduction of a minimum tax for multinational enterprise groups and large domestic groups’ to implement the OECD Administrative Guidance. On December 28, 2023, the Belgian Official Gazette published the ‘Act on the introduction of a minimum tax for multinational enterprise groups and large domestic groups’ to implement the EU Minimum Tax Directive from January 1, 2024. On November 30, 2023, the Belgian House of Representatives adopted the draft law No. 55K3678 to implement the EU Minimum Tax Directive. The law will be enacted after it has been promulgated by the King and published in the official journal. The draft law was passed with no amendments. On November 13, 2023, draft law No. 55K3678 to implement the EU Minimum Tax Directive was sent to the Belgian Parliament. | Yes (Accounting periods beginning on or after December 31, 2023) | Yes (Accounting periods beginning on or after December 31, 2024) | Yes (Accounting periods beginning on or after December 31, 2023) | Yes – Transitional CbCR Safe Harbour Draft law includes the Transitional UTPR Safe Harbour, QDMTT Safe Harbour and the NMCE Safe Harbour | Belgian Royal Decree Sets July 13, 2024 as the Deadline for the First GloBE Notification Form Belgium Issues Draft Law to Implement the OECD Administrative Guidance A Review of Belgium’s Draft Pillar Two Law |
| Bulgaria | Bulgaria: GloBE Country Guide | Yes | On December 22, 2023, the Law Amending the Corporate Income Tax Act (to implement the EU Minimum Tax Directive), was published in Issue 106 of the Official Gazette. On December 13, 2023, the Bulgarian Parliament approved the amendments to the Corporate Income Tax Act to implement the Pillar 2 GloBE rules. On September 26, 2023, the Bulgarian Ministry of Finance issued a draft law for the implementation of the EU Global Minimum Tax Directive. | Yes (Accounting periods beginning on or after December 31, 2023) | Yes (Accounting periods beginning on or after December 31, 2024) | Yes (Accounting periods beginning on or after December 31, 2023) | Yes – Transitional CbCR Safe Harbour and Non-Material Constituent Entity Safe Harbour | A Review of Bulgaria’s Draft Pillar Two Law |
| Canada | Canada: GloBE Country Guide | Yes (When tabled for first reading if a majority government, otherwise after the third reading in the House of Commons) | On June 20, 2024, the Global Minimum Tax Act (included in the Budget Implementation Act 2024, No. 1) received royal assent. This includes provisions to implement an IIR and a QDMTT from December 31, 2023. Draft Global Minimum Tax Act | Yes (Accounting periods beginning on or after December 31, 2023) | No | Yes (Accounting periods beginning on or after December 31, 2023) | Yes – Transitional CbCR and QDMTT Safe Harbours | A Review of Canada’s Draft GloBE Law |
| Croatia | Croatia: GloBE Country Guide | Yes | On December 22, 2023, Law No 155/23, to implement the EU Minimum Tax Directive, was published in the Official Gazette. On November 30, 2023, the Croatian government sent a draft bill to Parliament to implement the Pillar Two GloBE rules. | Yes (Accounting periods beginning on or after December 31, 2023) | Yes (Accounting periods beginning on or after December 31, 2024) | Yes (Accounting periods beginning on or after December 31, 2023) | Yes – Transitional CbCR Safe Harbour | |
| Cyprus | Cyprus: GloBE Country Guide | No (After approval by Parliament) | On October 3, 2023, the Cyprus Ministry of Finance issued the ‘Ensuring a Global Minimum Level of Taxation of Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union Law of 2023’ to implement the Pillar Two GloBE rules/EU Minimum Tax Directive. | Yes (Accounting periods beginning on or after December 31, 2023) | Yes (Accounting periods beginning on or after December 31, 2024) | From January 1, 2025 | On July 24, 2024, the Ministry of Finance announced the domestic application of all OECD Safe Harbours as provided in the Safe Harbours & Penalty Relief Guidance and other Administrative Guidance. | A Review of Cyprus’s Draft Pillar Two Law |
| Czech Republic | Czech Republic: GloBE Country Guide | Yes | On April 26, 2024, the Czech government issued a draft law to amend the minimum tax act to implement aspects of the OECD Administrative Guidance. On December 29, 2023, Law 416/2023, to implement the EU Minimum Tax Directive, was published in the Czech Official Gazette. Draft Top-Up Tax Act of December 1, 2023 | Yes (Accounting periods beginning on or after December 31, 2023) | Yes (Accounting periods beginning on or after December 31, 2024) | Yes (Accounting periods beginning on or after December 31, 2023) | Yes – CbCR Safe Harbour, QDMTT Safe Harbour and the Transitional UTPR Safe Harbour | A Review of the Czech Draft Top-Up Tax Act |
| Denmark | Denmark: GloBE Country Guide | Yes | On June 11, 2024, Law No. 684 was published in the Danish Official Gazette. This implements additional aspects of the OECD Administrative Guidance. The Danish Minimum Taxation Act was enacted as Law No. 1535 of December 12, 2023. On June 23, 2023, the Danish Ministry of Taxation issued the Draft Minimum Tax Act | Yes (Accounting periods beginning on or after December 31, 2023) | Yes (Accounting periods beginning on or after December 31, 2024) | Yes (Accounting periods beginning on or after December 31, 2023) | Yes – CbCR Safe Harbour, QDMTT Safe Harbour + Transitional UTPR Safe Harbour | A Review of the Danish Draft Minimum Tax Act |
| Estonia | Estonia: GloBE Country Guide | Yes (After approval by Parliament) | On May 2, 2024, the Estonian Official Gazette enacted the ‘Act supplementing the Tax Information Exchange Act, the Tax Administration Act and the Income Tax Act’ to implement the EU Global Minimum Tax Directive. On February 8, 2024, the Government approved the ‘Act supplementing the Tax Information Exchange Act, the Tax Organisation Act and the Income Tax Act’ which includes provisions to implement Article 50 of the EU Minimum Tax Directive. | Article 50 Postponement | Article 50 Postponement | No | No | – |
| 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 | The New Zealand and EU Approaches to the Domestic Income Inclusion Rule (DIIR) Review of the Draft EU Pillar Two Directive Full Steam Ahead For EU Pillar Two Implementation |
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| Finland | Finland: GloBE Country Guide | Yes | On December 28, 2023, the Finnish President approved the ‘Law on the Minimum Taxation for Corporations’, which implements the EU Minimum Tax Directive. On August 15, 2023, the Finnish Ministry of Finance issued a draft law for the implementation of the EU Global Minimum Tax Directive | Yes (Accounting periods beginning on or after December 31, 2023) | Yes (Accounting periods beginning on or after December 31, 2024) | Yes (Accounting periods beginning on or after December 31, 2023) | Transitional CbCR Safe Harbour | Key Aspects of Finland’s Draft GloBE Law |
| France | France: GloBE Country Guide | Yes | On December 30, 2023, the French Official Gazette published the 2024 Finance Act. This includes provisions to enact the EU Minimum Tax Directive. Article 4 of the French 2024 Finance Bill (published on September 27, 2023) includes provisions to implement the EU Global Minimum Tax Directive. | Yes (Accounting periods beginning on or after December 31, 2023) | Yes (Accounting periods beginning on or after December 31, 2024) | Yes (Accounting periods beginning on or after December 31, 2023) | Yes – Transitional CbCR Safe Harbour, QDMTT Safe Harbour and the Transitional UTPR Safe Harbour | A Review of France’s Draft Pillar Two Law |
| Germany | Germany: GloBE Country Guide | Yes | On December 27, 2023, Germany’s law to implement the Pillar 2 GloBE Rules/EU Minimum Tax Directive was published in the Federal Law Gazette. On December 15, 2023, the Bundesrat (Germany’s Upper House of parliament) passed the Global Minimum Tax Act. It requires Presidential approval for enactment. On November 10, 2023, the Bundestag (Lower House) approved the German draft law to implement the EU 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, Transitional UTPR Safe Harbour & the QDMTT Safe Harbour) | Germany Approves and Updates its GloBE Law Amendments to Germany’s Pillar 2 Regime in the Updated Draft Law Germany Publishes Draft Global Minimum Tax Legislation |
| Greece | Greece: GloBE Country Guide | Yes (Approval by Parliament) | On April 5, 2024, Law 5100/2024 was published in the Official Gazette. This implements the EU Minimum Tax Directive in Greece from December 31, 2023 (with the UTPR applying from December 31, 2024). On February 22, 2024, the Ministry of National Economy and Finance entitled issued a draft law to implement the EU Global Minimum Tax Directive. | Yes (Accounting periods beginning on or after December 31, 2023) | Yes (Accounting periods beginning on or after December 31, 2024) | Yes (Accounting periods beginning on or after December 31, 2023) | Yes (CbCR Safe Harbour, Simplified Calculation Safe Harbour, Transitional UTPR Safe Harbour & the QDMTT Safe Harbour) | A Review of Greece’s Draft Pillar Two Law |
| Hungary | Hungary: GloBE Country Guide | Yes | On October 29, 2024, Hungary issued its Autumn 2024 Tax Package proposal. This included minor changes to the Pillar Two law. Most notably it expanded on the registration requirements. On November 30, 2023, Act LXXXIV of 2023 on ‘Additional taxes ensuring a global minimum tax level and amending certain tax laws in connection with this’ was published in issue 171/2023 of the Hungarian Gazette. | Yes (Accounting periods beginning on or after December 31, 2023) | Yes (Accounting periods beginning on or after December 31, 2024) | Yes (Accounting periods beginning on or after December 31, 2023) | Yes – Transitional CbCR Safe Harbour and the QDMTT Safe Harbour | A Review of Hungary’s Draft Pillar Two Law |
| Indonesia | – | No (Approval by the President and Parliament given but awaiting detailed requirements) | 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 |
| Ireland | Ireland: GloBE Country Guide | Yes | On December 18, 2023, the Irish President enacted the Finance (No. 2) Act 2023 (Act 39 of 2023) to implement the EU Minimum Tax Directive. On October 19, 2023, the Irish Ministry of Finance released the Finance (No. 2) Bill 2023. This inserts a new Part 4A into the Taxes Consolidation Act, 1997 to implement the Pillar Two GloBE rules/EU Minimum Tax Directive. On July 27, 2023, Ireland issued its Second Feedback Statement on Pillar Two. 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, included in the law. | Yes CbCR, UTPR and QDMTT Safe Harbours. Simpliied Reporting Election/Safe Harbour is also included. | 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 |
| Italy | Italy: GloBE Country Guide | Yes | On July 3, 2024, the Italian Ministry of Economy & Finance issued a Decree which contains the procedures for the implementation of the Qualified Domestic Minimum Top-up Tax. On May 21, 2024, Italy’s Ministry of Economy & Finance issued a Decree for the detailed application of the Transitional CbCR and UTPR Safe Harbours. On December 28, 2023, the Italian Official Gazette published Legislative Decree No. 209 of December 27, 2023 which implements the EU Minimum Tax Directive. On September 11, 2023, the Italian Ministry of Finance issued a draft law for the implementation of the EU Global Minimum Tax Directive. | Yes (Accounting periods beginning on or after December 31, 2023) | Yes (Accounting periods beginning on or after December 31, 2024) | Yes (Accounting periods beginning on or after December 31, 2023) | Yes CbCR, UTPR and QDMTT Safe Harbours. | A Review of Italy’s Draft Pillar Two Law |
| Japan | Japan: GloBE Country Guide | Yes (Passage by the Diet) | On April 12, 2024, the “Ministerial Ordinance to Partially Amend the Enforcement Regulations of the Corporation Tax Law” was published in the Official Gazette. This includes tax return forms (in Japanese) for reporting top-up tax under Japan’s Income Inclusion Rule. The top up forms are included in Appendix 20 of the Enforcement Regulations to the Corporation Tax Law, and can be viewed at: Top-up tax forms. On December 25, 2023, Japan’s National Tax Agency issued Frequently Asked Questions on the Japanese Income Inclusion Rule. On October 20, 2023, the Japanese Ministry of Finance released its technical explanation of the Japanese Global Minimum Tax Laws and Regulations. On June 30, 2023, Japan’s Ministry of Finance issued Ministry of Finance Ordinance No. 47 of 2023, Amending the Enforcement Regulations of the Corporation Tax Act. On June 16, 2023, a Cabinet Order to Partially Amend the Enforcement Order of the Corporation Tax Law (Cabinet Order No. 208) was published in the Official Gazette. 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 | Transitional CbCR Safe Harbour | Overview of Japan’s Latest Ministerial Ordinance on Pillar 2 Overview of Japan’s Cabinet Order on the Global Minimum Tax Japan’s Global Minimum Tax Law Is Enacted |
| Latvia | Latvia: GloBE Country Guide | Yes (Presidential assent required) | On June 20, 2024, the Latvian global minimum tax law was published in the Official Gazette. On January 30, 2024, Latvia issued a Draft Law to postpone the application of the GloBE rules under Article 50 of the EU Minimum Tax Directive. | Article 50 Postponement | Article 50 Postponement | No | No | Latvia Issues Draft Pillar Two Law & Confirms Postponement |
| Liechtenstein | Liechtenstein: GloBE Country Guide | Yes | On March 28, 2024, the Decree on the minimum taxation of large groups of undertakings (the ‘GloBE Regulation’) was published in the Official Gazette. On December 22, 2023, the Minimum Tax Act (to implement the EU Minimum Tax Directive), was published in the Official Gazette of Liechtenstein, No. 2023/484. 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 |
| Lithuania | Lithuania: GloBE Country Guide | Yes (Presidential assent required) | On June 19, 2024, the Lithuanian global minimum tax law was published in the Official Gazette. This implements the Article 50 deferral of the EU Minimum Tax Directive. On October 27, 2023, Lithuania’s Ministry of Finance issued a draft law to postpone the application of the GloBE rules under Article 50 of the EU Minimum Tax Directive. On March 14, 2024, the Lithuanian Parliament updated the draft GloBE Law. | Article 50 Postponement | Article 50 Postponement | No | No | Lithuania Issues Draft Pillar Two Law & Confirms Postponement |
| Luxembourg | Luxembourg: GloBE Country Guide | Yes (Ratfication by the Grand-Duc required) | On December 22, 2023, the Luxembourg Official Gazette published Law A864 to transpose the EU Minimum Tax Directive. On November 13, 2023, the Luxembourg Government issued amendments to update its draft law implementing the EU Minimum Tax Directive. On 4 August 2023, the Luxembourg government issued Draft Law No. 8292 to implement the EU Minimum Tax Directive. | Yes (Accounting periods beginning on or after December 31, 2023) | Yes (Accounting periods beginning on or after December 31, 2024) | Yes (Accounting periods beginning on or after December 31, 2023) | Yes – CbCR Safe Harbour, QDMTT Safe Harbour, UTPR Safe harbour, Permanent Safe Harbour, NMCE Safe Harbour | Luxembourg Updates its Draft GloBE Law for OECD Administrative Guidance Key Aspects of Luxembourg’s Draft GloBE Law |
| Malaysia | Malaysia: GloBE Country Guide | Yes (Announcement by the Minister during the Budget Speech and the issue of the Bill) | On December 29, 2023, the Finance Act (No. 2) 2023 was published in the Official Gazette. This implements the Pillar Two GloBE rules in Malaysia from 2025. On December 13, 2023, the Finance (No. 2) Bill, 2023 was passed by the Malaysian Parliament. | Yes (Accounting periods beginning on or after January 1, 2025) | No | Yes (Accounting periods beginning on or after January 1, 2025) | Yes – Transposed from OECD Guidance | A Review of Malaysia’s Draft Pillar Two Law |
| Malta | Malta: GloBE Country Guide | Yes | On February 28, 2024, the Maltese Tax Authorities issued a guidance note on the implementation of the EU Minimum tax Directive in Malta. On February 20, 2024, the Government issued Legal Notice 32 of 2024 which includes Regulations to implement Article 50 of the EU Minimum Tax Directive. However, as Malta intends to delay the application of the GloBE rules under Article 50 of the EU Directive, the law is not comprehensive and only covers limited aspects of the GloBE rules (as required for the application of Article 50). | Article 50 Postponement | Article 50 Postponement | No | No | – |
| Mauritius | – | No (Presidential assent given but detailed requirements required) | 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 |
| New Zealand | New Zealand: GloBE Country Guide | Yes (After the Third reading in Parliament) | The Taxation (Annual Rates for 2023-24, Multinational Tax, and Remedial Matters) Act, 2024 has been enacted, receiving Royal assent, March 28, 2024. 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. This was Updated on March 11, 2024 | Yes | Yes | No (Domestic IIR from January 1, 2026) | Yes | 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 |
| Norway | Norway: GloBE Country Guide | Yes (Approved by Parliament) | On January 12, 2024, the Norwegian Council of State ratified the Norwegian Parliaments enactment of the Supplementary Tax Act in Legislative Decision 37 (2023-2024) Act No. 1. (see Law-2024-01-12-1 ) On November 24, 2023, the draft law to implement the GloBE rules in Norwegian law from 2024 was submitted to Parliament. On June 6, 2023, the Norwegian Ministry of Finance launched a consultation (including draft legislation) on the implementation of the Pillar Two GloBE Rules in Norway. | Yes (Accounting Periods beginning on or after January 1, 2024) | No | Yes (Accounting Periods beginning on or after January 1, 2024) | Yes – CbCR Safe Harbour + Penalty Relief | Norway Issues Consultation and Draft Law For Pillar 2 Rules |
| Poland | Poland: GloBE Country Guide | No (Signature of the President) | On April 25, 2024, the Polish Ministry of Finance issued a Draft Law to implement the EU Minimum Tax Directive. | Yes (Effective January 1, 2025, unless an election is made to apply from January 1, 2024) | Yes (Effective January 1, 2025, unless an election is made to apply from January 1, 2024) | Yes (Effective January 1, 2025, unless an election is made to apply from January 1, 2024) | Yes – CbCR Safe Harbour, QDMTT Safe Harbour, UTPR Safe harbour, NMCE Safe Harbour | – |
| Portugal | Portugal: GloBE Country Guide | Yes | On July 10, 2024, the Portuguese government issued a draft law to transpose the EU Minimum Tax Directive into domestic law. The public consultation is open until 31 July 2024. | Yes (Fiscal years beginning on or after January 1, 2024) | Yes (Fiscal years beginning on or after January 1, 2025) | Yes (Fiscal years beginning on or after January 1, 2024) | Yes, CbCR Safe harbour, NMCE Simplified Calculations, Transposed OECD Safe Harbours | |
| Romania | Romania: GloBE Country Guide | Yes | On December 29, 2023, Law No. 431/2023 to implement the EU Minimum Tax Directive was published in the Official Gazette. On December 19, 2023, the Romanian Parliament approved the ‘Draft Law on ensuring a global minimum level of taxation for MNE Groups and Large National Groups’. On October 4, 2023, the Romanian Ministry of Finance issued a draft law to implement the Pillar Two GloBE rules/EU Minimum Tax Directive. | Yes (Accounting periods beginning on or after December 31, 2023) | Yes (Accounting periods beginning on or after December 31, 2024) | Yes (Accounting periods beginning on or after December 31, 2023) | Yes – Transitional CbCR Safe Harbour, the Simplified Calculations Safe Harbour (to be determined) and the Non-Material Constituent Entity Safe Harbour. | A Review of Romania’s Draft Pillar Two Law |
| Singapore | Singapore: GloBE Country Guide | No | Draft Multinational Enterprise (Minimum Tax) Bill of June 10, 2024 Draft Multinational Enterprise (Minimum Tax) Regulations 2025 of June 10, 2024 | Yes (Accounting Periods beginning on or after January 1, 2025) | No | Yes (Accounting Periods beginning on or after January 1, 2025) | Yes – Regulation to be issued for detailed rules | – |
| Slovakia | Slovakia: GloBE Country Guide | Yes | On December 23, 2023, Act No. 507/2023 was published in the Official Gazette, to implement the EU Minimum Tax Directive from January 1, 2024. On December 4, 2023, the Slovakian Government approved the ‘Draft Act on the Equalization Tax to ensure a minimum level of taxation for multinational enterprise groups and large national groups’. It also approved a proposal for an accelerated legislative procedure to enact the law. The draft law has now been passed to the Legislative Council. | No | No | Yes (Accounting periods beginning on or after December 31, 2023) | Yes – Transitional CbCR Safe Harbour | Slovakia’s GloBE Law Applies the EU’s IIR/UTPR Postponement Provision |
| Slovenia | Slovenia: GloBE Country Guide | Yes | On December 22, 2023, the Minimum Tax Act (to implement the EU Minimum Tax Directive), was published in the Official Gazette of the Republic of Slovenia, No. 131/23. | Yes (Accounting periods beginning on or after December 31, 2023) | Yes (Accounting periods beginning on or after December 31, 2024) | Yes (Accounting periods beginning on or after December 31, 2023) | Yes – Transitional CbCR Safe Harbour | – |
| South Africa | South Africa: GloBE Country Guide | No (Presidential Approval required) | On February 21, 2024, the National Treasury and the South African Revenue Service issued the Draft Global Minimum Tax Bill, and the Draft Global Minimum Tax Administration Bill. | Yes (Accounting periods beginning on or after January 1, 2024) | No | Yes (Accounting periods beginning on or after January 1, 2024) | Yes – Transitional CbCR Safe Harbour, QDMTT Safe Harbour, Transitional UTPR Safe Harbour; and the Simplified calculation for Non-Material Constituent Entities Safe Harbour | South Africa Issues a Draft Law to Transpose the OECD GloBE Rules & Adopts an ‘Ambulatory’ Approach |
| South Korea | South Korea: GloBE Country Guide | Yes (Presidential promulgation) | On July 25, 2024, the Ministry of Economy and Finance issued the 2024 Tax Law Amendment Bill. This includes a number of amendments to the South Korean global minimum tax law to reflect aspects of the OECD Administrative Guidance. On March 22, 2024, the Enforcement Regulations to the International Tax Adjustment Act were amended for GloBE adjustments. This includes attachments for the GIR (in English and Korean) and the GloBE Tax Return. On February 29, 2024, the Enforcement Decree to the International Tax Adjustment Act was amended to reflect aspects of the GloBE rules. On December 31, 2022, South Korea passed Law 19191 to amend the International Tax Adjustment Act to provide for the Pillar Two Global Minimum Tax from January 1, 2024. On December 31, 2023, Law 19928 was issued to amend the International Tax Adjustment Act. to amend their Pillar Two law to (1) take account of a number of OECD amendments issued in their Administrative Guidance, and (2) delay the implementation of the UTPR until January 1, 2025. On November 9, 2023, South Korea issued the Preliminary Legislative Notice of Partial Amendment to the Enforcement Decree of the International Tax Adjustment Act | Yes (Accounting Periods beginning on or after January 1, 2024) | Yes (Accounting Periods beginning on or after January 1, 2025). | No | Yes – Transitional CbCR Safe Harbour + QDMTT Safe Harbour. Transitional UTPR Safe Harbour is included in the 2024 Tax Law Amendment Bill. | A Review of South Korea’s Pillar Two Amendments to its Enforcement Regulation A Review of South Korea’s Latest GloBE Amendments South Korea Issues Draft Pillar 2 Amendment Law 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 |
| Spain | Spain: GloBE Country Guide | No (Approval by Parliament required) | On December 19, 2023, Spain’s Council of Ministers approved a draft law to implement the EU Minimum Tax Directive. It was subject to a consultation and was then subsequently approved as a second draft by the Council of Ministers on June 4, 2024. On June 14, 2024, the Official Gazette of the Spanish Parliament published the text of the Bill. The first draft law was published on December 20, 2023 | Yes (Accounting periods beginning after December 31, 2023) | Yes (Accounting periods beginning after December 31, 2024) | Yes (Accounting periods beginning after December 31, 2023) | Yes – Transitional CbCR Safe Harbour, Transitional UTPR Safe Harbour, Agreed International QDMTT Safe Harbour | – |
| Sweden | Sweden: GloBE Country Guide | Yes (Approval by Parliament required) | On March 19, 2024, the Swedish Ministry of Finance published proposals, including draft legislation, to amend its GloBE law to include further aspects of the OECD Administrative Guidance. On December 16, 2023, the Swedish Official Gazette published Law No. SFS 2023:875, implementing the EU Minimum Tax Directive. | 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)) | Yes – CbCR Safe Harbour. Draft law includes QDMTT Safe Harbour, UTPR Safe Harbour and the NMCE Simplified Calculation Safe Harbour | See our Review of the Draft Swedish Global Minimum Tax Law |
| Switzerland | Switzerland: GloBE Country Guide | Yes (Approval by Parliament required) | On December 22, 2023, the Swiss Federal Council issued an Ordinance and announced Switzerland is to apply a QDMTT from December 31, 2023. The IIR and UTPR are to be delayed. 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. | Planned for Accounting Periods beginning on or after January 1, 2025) | Planned for 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 |
| Thailand | Thailand: GloBE Country Guide | No (Approval by the Monarch required) | On March 1, 2024, the Thai Revenue Department published a draft law on the implementation of Pillar Two. | Yes (Accounting Periods beginning on or after January 1, 2025) | Yes (Accounting Periods beginning on or after January 1, 2025) | Yes (Accounting Periods beginning on or after January 1, 2025) | None | – |
| The Netherlands | Netherlands: GloBE Country Guide | Yes (Approval of both Houses of Parliament required) | On December 27, 2023, the Dutch Official Gazette published the 2024 Tax Plan which includes the Minimum Tax Act to implement the EU Minimum Tax Directive. On 13 October 2023, the Dutch State-Secretary of Finance issued a Bill to amend the Dutch Draft Minimum Tax Bill. The Minimum Tax Bill was presented to Parliament on May 31, 2023 | Yes (Accounting periods beginning from December 31, 2023) | Yes (Accounting periods beginning from December 31, 2024) | Yes (Accounting periods beginning from December 31, 2023) | Yes – CbCR Safe Harbour and the QDMTT and Transitional UTPR Safe Harbours | The Netherlands Issues GloBE Amendments for OECD Administrative Guidance The Netherlands Sends GloBE Minimum Tax Bill to Parliament |
| United Kingdom | United Kingdom: GloBE Country Guide | Yes (after the Third Reading in the House of Commons) | On May 20, 2024, the UK issued a Pillar 2 top-up taxes registration notice, that explains how to register for Pillar 2 top-up taxes in the UK, the information required and how to notify HMRC of any reporting related changes. On February 22, 2024, the Finance Act 2024 received Royal Assent. Finance (No. 2) Act for the ‘Multinational Top-Up Tax‘ was enacted on July 11, 2023. On June 15, 2023, the UK issued draft guidance on the application of the multinational top-up tax. On September 27, 2023, the UK government amended the draft legislation to be included in the 2024 Finance Bill. | Yes (Accounting periods beginning on or after December 31, 2023) | Proposed | Yes (Accounting periods beginning on or after December 31, 2023) | Yes – CbCR Safe Harbour (anti-avoidance rules targeting Hybrid Arbitrage Arrangements to apply from March 14, 2024) and the QDMTT Safe Harbour. | 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 Review of the UK Global Minimum Tax in Yesterday’s 2023 Spring Finance Bill |
| Vietnam | Vietnam: GloBE Country Guide | Yes (Approval of the Government) | On December 8, 2023, Resolution No: 107/2023/QH15 was issued to enact the Pillar Two GloBE rules. It was published in the Vietnamese Official Gazette on December 21, 2023 | Yes (Accounting Periods beginning on or after January 1, 2024) | No | Yes (Accounting Periods beginning on or after January 1, 2024) | Yes – CbCR Safe Harbour | – |
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