Article 2.10 of the February 2023 OECD Administrative Guidance provides more information on the treatment of the US Global Intangible Low-Taxed Income (GILTI) regime.
This is to be treated as a blended CFC Regime for GloBE purposes. Under the GloBE Rules CFC taxes are allocated to the foreign CFC (subject to the push down restriction). The GloBE Commentary doesn’t go into detail on the allocation and just provides that the CFC tax should be allocated to each CFC based on the owner’s share of the underlying income.
However, determining the allocation can be tricky when there is a blended CFC regime.
The December 2023 OECD Administrative Guidance provides additional information on the application of the Blended CFC rules, including:
– where an MNE Group calculates multiple GloBE Jurisdictional ETRs for different types of Entities located in the same jurisdiction (eg a separate GloBE ETR for investment entities or JVs),
– where an MNE Group is not required to calculate an ETR as they claim the Transitional CbCR Safe Harbour or the QDMTT Safe Harbour, or if the De Minimis exclusion applies
– where a Constituent Entity is subject to a Blended CFC Tax Regime on the income of non-GloBE Entities.
SubCo1: 20,000/520,000 * 1.5 million = 57,692 euros
SubCo2: No Allocation
SubCo3: 500,000/520,000 * 1.5 million = 1,442,308 euros
Subsco1CE: 15,000/520,000 * 1.5 million = 43,269 euros
SubCo2: No Allocation
SubCo3: 500,000/520,000 * 1.5 million = 1,442,308 euros
On August 26, 2025, Australia issued a list of jurisdictions that have qualified status for the purposes of the income inclusion rule and domestic minimum tax (including the QDMTT Safe Harbour).
On August 27, 2025, the Australian Taxation Office issued a draft legislative instrument (the ‘Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR tax return and Australian DMT tax return) Determination 2025’). This outlines situations when entities within the scope of the Pillar 2 GloBE rules do not need to file an Australian DMT Return or an IIR/UTPR Return.
On August 20, 2025, the Romanian government issued a draft law for consultation. The law proposes amendments to various aspects of the Minimum Tax Act, including for the filing deadline for the designated filing entity nomination, transferable tax credits and the excess negative tax carry forward election.
The Finance Act 2025, enacted on August 8, 2025, introduces a new Sub-Part AF to the Income Tax Act to include a domestic minimum top-up tax (intended to be a QDMTT) from July 1, 2025.
On January 15, 2025, the OECD issued Administrative Guidance that includes a list of jurisdictions that have transitional qualified status for the purposes of the income inclusion rule and domestic minimum tax (including the QDMTT Safe Harbour). This was subsequently updated on March 31, 2025 and August 18, 2025.
On August 6, 2025, Germany issued the draft bill to amend the Minimum Tax Act. This follows the two previous discussion drafts and now includes the January 2025 OECD Administrative Guidance and DAC9 amendments.
On March 20, 2025, the Swedish Ministry of Finance issued a proposal to amend the Global Minimum Tax Act. The final draft law was published by the government on August 14, 2025. The purpose of the draft law is to implement the provisions of the June 2024 OECD Administrative Guidance into domestic law.
On August 13, 2025, Canada issued draft legislative proposals to amend its Global Minimum Tax Act to provide for aspects of the June 2024 and January 2025 OECD Administrative Guidance.
Many jurisdictions will require GloBE registration for administrative purposes, however, the law issued to date has been inconsistent. We outline the GloBE registration obligations from the domestic legislation (enacted and draft) issued to date, with citations and links to relevant laws.
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