Pillar Two Implementation

General

The July 2021 OECD Statement on a Two-Pillar Solution provided that the Pillar Two GloBE rules have the status of a ‘common approach’. This means that members of the Inclusive Framework (IF) are not required to adopt them (ie they are not compulsory), but, if they do, they need to implement and administer them in a way that is consistent with the outcomes provided for under Pillar Two.

In addition, members of the IF are required to accept the application of the GloBE rules applied by other members, including (crucially) agreement on the rule order and the application of any agreed safe harbors.

If jurisdictions do want to implement the GloBE rules, both the Income Inclusion Rule (IIR) and Under-taxed Payments Rule (UTPR) will need to be implemented through domestic legislation.

The Subject-To-Tax Rule (STTR), as a treaty-based rule, can only be implemented through bilateral negotiations and amendments to individual treaties or as part of a multilateral convention.

The OECD provides that members of the IF that apply nominal corporate income tax rates below the STTR minimum rate will implement the STTR into their bilateral treaties with developing country members of the IF when requested to do so.

On July 11, 2023, the OECD issued an Outcome Statement on Pillars 1 & 2 that gives an update on the status and timeline for implementation of Amount A and B of Pillar One, and the Subject-to-Tax Rule (STTR).

On July 17, 2023, the OECD issued the STTR model provision and commentary. The Multilateral Instrument implementing the STTR was released and open for signature from October 2, 2023.

On October 11, 2023, the OECD released the Minimum Tax Implementation Handbook.

The Implementation Handbook is divided into two chapters:

-The first chapter provides an overview of the global minimum tax

-The second chapter sets out the considerations to be taken into account in assessing implementation options.

On December 18, 2023, the OECD issued the Third Set of Administrative Guidance on the Pillar Two GloBE Rules. It covers:

-Purchase price accounting adjustments in Qualified Financial Statements

-Further Guidance on the Transitional CbCR Safe Harbour

-Administrative Guidance on application of GloBE Rules

-Further Administrative Guidance on the allocation of Blended CFC Taxes

-Transitional Filing Deadlines for MNE Groups with Short Reporting Fiscal Years

-Simplified Calculation Safe Harbour for Non-Material Constituent Entities

On April 25, 2024, the OECD issued its Updated Commentary to the Model GloBE Rules. This includes the amendments and additions from the 2023 OECD Administrative Guidance.

On June 17, 2024, the Fourth set of OECD Administrative Guidance was issued.

In the July 2024 OECD Secretary-General Tax Report to G20 Finance Ministers, it was announced that the first high-level ceremony for the Multilateral Convention to facilitate the implementation of the STTR will take place in Paris on September 19, 2024.

The original timeframe was that Pillar Two should be brought into law in 2022, with the IIR coming into effect in 2023 and the UTPR in 2024.

Implementation Delayed However, this timeline has been pushed back. The EU has enacted a Global Minimum Tax Directive (see below) that requires EU jurisdictions to enact domestic legislation for the IIR from 2024 and the UTPR from 2025.

A number of other jurisdictions have published proposals for the domestic enactment of Pillar Two, with commencement from 2024.

However, certain jurisdictions (eg Singapore and Hong Kong) are planning to implement the GloBE rules from 2025.

See: Impact of the Staggered Implementation of the GloBE Rules.

International Implementation

The OECD published Model GloBE rules in December 2021 and Commentary in March 2022.

On December 20, 2022, the OECD issued the Safe Harbours and Penalty Relief: Global Anti-Base Erosion Rules (Pillar Two), which includes details of two safe harbours and penalty relief for the Pillar Two GloBE rules.

On February 2, 2023, the OECD issued the Agreed Administrative Guidance for the Pillar Two GloBE Rules. Running to 111 pages, it provides guidance on some of the outstanding issues that were left open in the Commentary issued in March 2022.

On July 17, 2023, the OECD issued its second set of Administrative Guidance on the application of the Pillar Two GloBE Rules (see: A Review of the OECDs Second Set of GloBE Administrative Guidance).

The European Commission released a Proposed Directive based on the model GloBE rules on December 22, 2021.

This was originally held up by Poland. They later relented but Hungary then raised objections in June 2022.

On June 30, 2022, the French Finance Minister announced that Pillar Two will be implemented with or without Hungary.

On September 9, 2022, Germany, France, Italy, Spain and the Netherlands issued a joint statement stating that if agreement is not reached on Pillar Two in ‘the next few weeks’ they will push forward domestic implementation of the Pillar Two GloBE rules ‘by any possible legal means’ in 2023. Belgium subsequently announced it is willing to participate in the enhanced cooperation procedure to implement Pillar Two GloBE Rules.

On December 12, 2022, the EU issued a press release stating that ‘the ambassadors of EU member states decided to advise the Council to adopt the Pillar 2 directive, and a written procedure for the formal adoption will be launched.’

On December 15, 2022, the Council of the European Union formally adopted the EU Pillar Two directive. Member states will have to transpose the directive into national law by the end of 2023.

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. Date of entry into force: 23 December 2022.

Numerous other jurisdictions have issued legislation to enact the Global Minimum Tax, with South Korea being the first domestic jurisdiction to enact legislation.

Use our Pillar Two Tracker to keep up to date with the latest developments.

Legislation

Country	GloBE Country Guide	Legislation	Guidance	Other Analysis
Australia	Australia: GloBE Country Guide	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.	Explanatory notes	Australia Submits Pillar 2 Laws to Parliament A Review of Australia’s Draft Pillar Two Legislation
Austria	Austria: GloBE Country Guide	On July 19, 2024, the Tax Amendment Act 2024 was published in the Official Gazette, which includes various amendments to the Minimum Tax Act arising from the OECD Administrative Guidance, including currency provisions, extending the Transitional CbCR Safe Harbour to cases where an MNE is not required to prepare CbC Reports, and MTTCs. 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. See our English Translation	Explanatory Notes	Austria Updates Minimum Tax Act for Aspects of OECD Administrative Guidance A Review of Austria’s Draft Pillar Two Law
Bahamas	The Bahamas: GloBE Country Guide	On October 16, 2024, the government tabled in Parliament the Domestic Minimum Top-Up Tax Bill 2024, which seeks to introduce an effective tax rate of 15 percent via a QDMTT for in-scope multinational enterprises operating in The Bahamas that have an annual consolidated revenue of or above 750 million euros. On August 12, 2024, the Government of the Bahamas issued a consultation paper including draft legislation (the ‘Domestic Minimum Top-Up Tax Bill, 2024) on a domestic minimum top-up tax (‘DMTT’), intended to be a Qualified Domestic Minimum Top-Up Tax.		The Bahamas Issues a Policy Paper on a New CIT System, Including a QDMTT
Bahrain	Bahrain: GloBE Country Guide	On September 1, 2024, Bahrain’s National Bureau for Revenue published Decree-Law No. (11) of 2024 for the introduction of a QDMTT.
Barbados	Barbados: GloBE Country Guide	On 7 May 2024, the Senate passed the Corporation Top-up Tax Bill, 2024 .	–	Bermuda and Barbados Announce GloBE Implementation
Belgium	Belgium: GloBE Country Guide	On October 18, 2024, Belgium issued a draft QDMTT Return for consultation. The consultation lasts until November 8, 2024. On 16 July 2024, Belgium published the Royal Decree of 7 July 2024 in the Official Gazette, which establishes the rules for companies to make advance payments of the minimum tax under Pillar 2. On May 29, 2024, the Royal Decree of 15 May 2024 was published in the Official Gazette. This sets the GloBE Notification requirements. 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 December 14, 2023, the Belgian parliament adopted the draft law to implement the EU Minimum Tax Directive. 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.	Tax Authority FAQs on the Belgian Registration Process	Belgium Issues a Draft 7 Page QDMTT Return for Consultation Belgium Extends Registration Deadline to September 16, 2024 if no 2024 GMT Advance Payments 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
Bermuda	–	On December 28, 2023, the Corporate Income Tax Act, 2023 (Act No. 35/2023) was published in the Official Gazette. On December 8, 2023, the Corporate Income Tax Act 2023 was tabled in the House of Assembly.		Bermuda Issues Draft Corporate Income Tax Law
Bulgaria	Bulgaria: GloBE Country Guide	On September 18, 2024, the Bulgarian Ministry of Finance published for public consultation draft legislation to amend the Bulgarian minimum taxation rules, including the introduction of the Transitional UTPR Safe Harbour. 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. The law needs to be signed by the President to be enacted. On September 26, 2023, the Bulgarian Ministry of Finance issued a draft law for the implementation of the EU Global Minimum Tax Directive. See our English Translation		Bulgaria Issues a Draft Law to Provide for OECD Administrative Guidance, Including the UTPR Safe Harbour A Review of Bulgaria’s Draft Pillar Two Law
Brazil	Brazil: GloBE Country Guide	On October 3, 2024, Brazil issued Provisional Measure No. 1,262, of October 3, 2024, to introduce a Domestic Minimum Tax from January 1, 2025. It is designed to meet the requirements of the OECD Model Rules and Administrative Guidance and qualify as a Qualified Domestic Minimum Top-Up Tax for GloBE purposes. Normative Instruction No. 2,228, of October 3, 2024 was also issued to regulate the application of the QDMTT. It now needs to be ratified by Congress.	–	Brazil Issues Legislation to Implement a QDMTT From January 1, 2025
Canada	Canada: GloBE Country Guide	On August 12, 2024, draft legislative proposals (the ‘2024 Draft Law’) were issued to provide for the Under-Taxed Profits Rule (UTPR) for fiscal years beginning on or after December 31, 2024 (as well as limited other amendments for the Fourth Set of OECD Administrative Guidance). 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. On August 4, 2023, Canada issued the draft Global Minimum Tax Act for consultation.	Explanatory Notes Table of Concordance	Canada Issues Explanatory Notes on the Global Minimum Tax A Review of Canada’s Draft GloBE Law
Croatia	Croatia: GloBE Country Guide	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 implement the Pillar Two GloBE rules to Parliament.	Explanation
Cyprus	Cyprus: GloBE Country Guide	On October 18, 2024, a bill was tabled in Parliament to introduce the mandatory Income Inclusion Rule (IIR) for fiscal years beginning from December 31, 2023, and the Undertaxed Profits Rule (UTPR) for fiscal years starting from December 31, 2024. A DMTT will be implemented for fiscal years beginning December 31, 2024. The IIR, which should have been approved by the end of 2023, will apply retroactively from December 31, 2023. 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. 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. See our English Translation		Portugal Approves Pillar 2 Law, Bahamas and Cyprus Table Legislation in Parliament A Review of Cyprus’s Draft Pillar Two Law
Czech Republic	Czech Republic: GloBE Country Guide	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. This was submitted to Parliament on August 28, 2024. On December 29, 2023, Law 416/2023, to implement the EU Minimum Tax Directive, was published in the Czech Official Gazette. On August 16, 2023, the Czech Cabinet approved the draft top-up tax act. On December 1, 2023, the Czech Senate approved the draft top-up tax act. See our English Translation	Explanatory Notes for the April 2024 Draft Law (December 2023 Administrative Guidance) Regulatory Report	Czech Republic Amends Draft Law Amending its GloBE Law A Review of the Czech Draft Top-Up Tax Act
Denmark	Denmark: GloBE Country Guide	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 (the ‘Bill’) to give effect to the GloBE rules.	Report of Committee on Taxation	Denmark GloBE Country Guide: Updated for June 2024 Amending Law A Review of the Danish Draft Minimum Tax Act
Estonia	Estonia: GloBE Country Guide	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 ‘Act supplementing the Tax Information Exchange Act, the Tax Administration Act and the Income Tax Act’ to implement the EU Global Minimum Tax Directive was approved by the Estonian Government and sent to Parliament. It was approved by Parliament on April 10, 2024. However, as Estonia intends to delay the application of the GloBE rules under Article 50 of the EU directive, the draft law is not comprehensive and only covers limited aspects of the GloBE rules (as required for the application of Article 50).		Estonia Issues Draft Pillar 2 Law Including Art. 50 Postponement
EU	–	On October 28, 2024, the EU Commission adopted a proposal to amend the Directive on administrative cooperation in the field of taxation (Directive 2011/16/EU – DAC) (DAC 9). The goal is to make it easier for companies to fulfil their filing obligations under the Pillar 2 Directive. On December 12, 2023 the EU Commission published the Commission Notice to Elect to delay application of the IIR and UTPR under Article 50 of the Pillar Two Directive. The European Commission released a proposed directive based on the model GloBE rules on December 22, 2021. On December 15, 2022, the Council of the European Union formally adopted the EU Pillar Two directive. Member states will have to transpose the directive into national law by the end of 2023. 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. Date of entry into force: 23 December 2022.	FAQ document	EU Issues DAC 9 Proposal for Centralised GIR Filing Within the EU The New Zealand and EU Approaches to the Domestic Income Inclusion Rule (DIIR) EU Issues Commission Notice For Jurisdictions Delaying the IIR/UTPR Full Steam Ahead For EU Pillar Two Implementation Review of the Draft EU Pillar Two Directive Poland Withdraws its Veto and the EU Pillar Two Directive is Adopted
Finland	Finland: GloBE Country Guide	On August 12, 2024, the Finnish government issued draft legislation to amend its Global Minimum Tax Act to reflect aspects of the 2023 OECD Administrative Guidance. The draft law is subject to a consultation until September 6, 2024. On September 19, 2024, the draft law to amend the Minimum Tax Act was sent to Parliament. 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. See our English Translation	Explanation	Finland Issues Draft Pillar 2 Amendment Law to Reflect OECD Administrative Guidance Key Aspects of Finland’s Draft GloBE Law
France	France: GloBE Country Guide	On 10 October 2024, the French Government presented the draft Finance Bill for 2025 to Parliament. This includes amendments to its GMT law to reflect the OECD Administrative Guidance, including the December 2023 OECD amendments to the Safe Harbours. On December 30, 2023, the French Official Gazette published the 2024 Finance Act. This includes provisions to enact the EU Minimum Tax Directive. On 21 December 2023, the French Parliament approved the Finance Bill for 2024. Article 4 of the French 2024 Finance Bill (published on September 27, 2023) includes provisions to implement the EU Global Minimum Tax Directive. See our English Translation		France GloBE Country Guide Updated for the 2025 Finance Bill A Review of France’s Draft Pillar Two Law
Germany	Germany: GloBE Country Guide	On October 17, 2024, Germany released the template for its Group Leader Notification Form. On August 20, 2024, the German Ministry of Finance issued a Discussion Draft of a Draft Law to implement most aspects of the Third Set of OECD Administrative Guidance. On June 5, 2024, the German Federal Ministry of Finance published the government draft for an Annual Tax Act 2024. This includes an amendment to the minimum tax act to implement the provision relating to the calculation of the SBIE for mobile employees in the Second Set of OECD Administrative Guidance. On May 17, 2024, the Germany Finance Ministry issued a draft Global Minimum Tax Return to specialist publishers, software providers and associations for feedback. 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 2023. The Bundesrat (Germany’s Upper House of parliament) passed the ‘Act on the implementation of Council Directive (EU) 2022/2523 to ensure a global minimum level of taxation and further accompanying measures’ . 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. On August 16, 2023, the Federal Cabinet adopted the government draft for the implementation of the Pillar Two GloBE Rules. On July 10, 2023, the German Ministry of Finance issued an updated draft law for the implementation of the EU Global Minimum Tax Directive. 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. See our English Translation		Germany Releases its Group Parent Notification Form for German Minimum Tax Groups Germany Includes an Amendment to its GMT Law in the Draft Annual Tax Act Germany Issues Draft GMT Return For Feedback 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	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. The draft law is subject to consultation until March 6, 2024. The draft law includes an IIR and QDMTT from December 31, 2023 and a UTPR from December 31, 2024.	Explanation	A Review of Greece’s Draft Pillar Two Law
Hong Kong		On October 30, 2024, the Hong Kong government released the outcome statement following the previous consultation into the introduction of the GloBE rules.	–	Hong Kong Issues Outcome of the Consultation on the Introduction of the GloBE Rules
Hungary	Hungary: GloBE Country Guide	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. See our English Translation	Explanation 1 Explanation 2	Hungary Includes GloBE Amendments in its 2024 Autumn Tax Proposal Hungary Approves and Updates its GloBE Law A Review of Hungary’s Draft Pillar Two Law
Isle of Man	Isle of Man: GloBE Country Guide	On October 24, 2024, the Isle of Man income tax division published an update on the implementation of the GloBE rules in a letter sent to all Isle of Man entities likely to be within the scope of the new rules. The draft legislation is available and will be considered by the Parliament in November 2024. The Isle of Man is applying an IIR and a QDMTT. The legislation transposes the GloBE model rules and commentary/AG into domestic law with some modifications.	–	Isle of Man Issues Draft Legislation for the IIR and QDMTT from 2025
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 as a desire to implement Pillar One.		Indonesian Regulation Signals Global Minimum Tax Implementation
Ireland	Ireland: GloBE Country Guide	On October 10, 2024, Ireland published its 2024 Finance Bill. In the Bill, a number of amendments are made to the Global Minimum Tax provisions. This was approved by the lower house of Parliament on November 5, 2024. On August 8, 2024, the Irish Revenue issued eBrief No. 213/24 concerning new guidance on the administration of the Pillar 2 global minimum tax, as well as updated guidance on the operation of the Pillar 2 rules. On December 22, 2023, the Minister of Finance issued S.I. No. 675/2023 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2023 to provide that the December 2023 OECD Adminstrative Guidance applies in Ireland. 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.	eBrief No. 213/24 Tax & Duty Manual: Pillar 2 Revenue eBrief No. 136/24 Explanation	Ireland GloBE Country Guide Updated for the 2024 Finance Bill A Review of Ireland’s Draft Pillar Two Law 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	On October 15, 2024, Italy issued Decree 11, of October 2024 on the calculation of the Substance-based Income Exclusion under Pillar 2. This includes all of the OECD Administrative Guidance on the SBIE. 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 (QDMTT). 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 (the ‘EU Directive’). See our English Translation	Explanatory Notes on the SBIE Decree Technical explanation of the Transitional Safe Harbours Decree	Italy Issues SBIE Decree to Implement the July 2023 and June 2024 OECD Administrative Guidance Detailed Analysis of the Italian QDMTT Implementing Decree Italy Issues a Decree for the Transitional CbCR & UTPR Safe Harbours A Review of Italy’s Draft Pillar Two Law
Japan	Japan: GloBE Country Guide	On April 26, 2024, the Japanese National Tax Agency issued detailed explanatory notes on the application of Japan’s Pillar Two law/ordinance. 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 to apply from April 1, 2024. On October 20, 2023, the Japanese Ministry of Finance released its technical explanation of the Japanese Global Minimum Tax Laws and Regulations. On March 28, 2023, Japan enacted a domestic law to give effect to the Pillar Two GloBE rules from April 1, 2024. 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 was published in the Official Gazette. On September 29, 2023, the National Tax Agency published the “Partial Revision of the Basic Circular on Corporate Tax” which provides some administrative guidance on various aspects of Japan’s GloBE law. 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 from April 2024. See our English Translation	Detailed Explanatory Notes Technical Explanation	Japan Issues Circular for Additional GloBE Guidance What Japan’s Cabinet Order on Pillar 2 Includes & Doesn’t Include 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 GloBE Country Guide: Japan
Jersey	Jersey: GloBE Country Guide	On October 22, 2024, Jersey enacted the Multinational Corporate Income Tax (Jersey) Law 202 and the Multinational Taxation (Global Anti-Base Erosion – IIR Tax) (Jersey) Law 202 to provide for the IIR and MCIT from January 1, 2025. Multinational Taxation (Global Anti-Base Erosion – IIR Tax) (Jersey) Law 202\| Multinational Corporate Income Tax (Jersey) Law 202 On August 14, 2024, the Jersey Assembly accepted for consideration a draft Pillar 2 law ‘Draft Multinational Taxation (Global Anti-Base Erosion – IIR Tax) (Jersey) Law 202’ to implement an IIR as well as a ‘Draft Multinational Corporate Income Tax (Jersey) Law 202’ to implement a new multinational corporate income tax.	Pillar 2 Review	Jersey Enacts Law for the IIR and the MCIT
Kenya	–	On 4 November 2024, the Tax Laws (Amendment) Bill 2024 was introduced to the lower house of Parliament. The Bill includes a proposal for a minimum top-up tax of 15%. The law is very high level and while based on the Model GloBE rules, based on the current draft law this would not be a QDMTT (eg no CFC pushdown restriction, no safe harbours and no provisions for additional tax). On May 13, 2024 the Finance Bill, 2024 was sent to the Kenyan parliament. It includes provisions to introduce a 15% domestic minimum top-up tax from January 1, 2025.	–	Kenya Includes a Domestic Minimum Tax in its 2024 Finance Bill
Latvia	Latvia: GloBE Country Guide	On June 20, 2024, the Latvian global minimum tax law was published in the Official Gazette. On June 6, 2024 the Latvian Parliament adopted in its final reading the “Law on ensuring the global minimum tax level of large groups of companies”, which implements the EU Global Minimum Tax Directive. However, as Latvia intends to delay the application of the GloBE rules under Article 50 of the EU directive, the draft law is not comprehensive and only covers limited aspects of the GloBE rules (as required for the application of Article 50).		Lithuania and Latvia Updates to the GloBE Country Guides Latvian Parliament Adopts Law to Implement EU Minimum Tax Directive Latvia Issues Draft Pillar Two Law & Confirms Postponement
Liechtenstein	Liechtenstein: GloBE Country Guide	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 GloBE Rules), 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. See our English Translation		Liechtenstein Gazettes Pillar Two Law A Review of the Liechtenstein GloBE Regulation Liechtenstein Publishes Draft Global Minimum Tax Law
Lithuania	Lithuania: GloBE Country Guide	On September 19, 2024, the Lithuanian government launched a public consultation on a draft bill to fully implement the OECD’s Pillar Two Model Rules as set out under the EU Minimum Tax Directive. This follows the previous partial implementation of the GloBE Rules to defer implementation under Article 50 of the EU Minimum Tax Directive. On June 21, 2024 the Order on the procedures for the submission of information notifications in relation to the implementation of the Pillar 2 was published in the Official Gazette. 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 June 6, 2024, the Lithuanian Parliament approved Law No. XIV-2680/2024 to implement the Art. 50 deferral in the EU Minimum Tax Directive. On March 14, 2024, the Lithuanian Parliament updated the draft GloBE Law. On October 27, 2023, Lithuania’s Ministry of Finance issued a draft law to implement the EU Global Minimum Tax Directive. However, as Lithuania intends to delay the application of the GloBE rules under Article 50 of the EU directive, the draft law is not comprehensive and only covers limited aspects of the GloBE rules (as required for the application of Article 50). See our English Translation		Lithuania GloBE Country Guide Updated for Latest Draft Law Lithuania GloBE Guide – Updated for the Order on Information Notices Lithuania Issues Draft Pillar Two Law & Confirms Postponement
Luxembourg	Luxembourg: GloBE Country Guide	On June 12, 2024, the Luxembourg Government published draft law amending the law of 22 December 2023 on the minimum effective taxation for multinational enterprise groups and large domestic groups. The draft law provides for a number of amendments in the December 2023 OECD Administrative Guidance.On October 31, 2024 additional amendments were made to the draft legislation to incorporate elements from the OECD June 2024 Administrative Guidance. On March 25, 2024, the Luxembourg Government issued a FAQ on its Pillar 2 law. On December 22, 2023, the Luxembourg Official Gazette published Law A864 to transpose the EU Minimum Tax Directive. Grand-Ducal Regulation of 22 December 2023 on the procedures for registration and deregistration, notification and filing of the information return for the supplementary tax with the Direct Tax Administration On 20 December 2023, the Luxembourg Parliament voted to approve the draft law n°8292 transposing 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. See our English Translations	FAQs	Luxembourg GloBE Guide Updated for October 2024 Amendments to Draft Law Luxembourg Government Approves Draft Law to Include Additional OECD Administrative Guidance Luxembourg Updates its Draft GloBE Law for OECD Administrative Guidance Key Aspects of Luxembourg’s Draft GloBE Law
Malaysia	Malaysia: GloBE Country Guide	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 Malaysian Parliament approved the Finance Bill (No.2) 2023.	FAQs	A Review of Malaysia’s Draft Pillar Two Law
Malta	Malta: GloBE Country Guide	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).	Guidance Notes	Malta Enacts EU Minimum Tax Directive With Art. 50 Postponement
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.		Mauritius 2022 Finance Act includes Pillar Two Top-Up Tax
New Zealand	New Zealand: GloBE Country Guide	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. On March 11, 2024, the Finance and Expenditure Committee of the New Zealand Parliament made a number of amendments to the draft law.	Commentary	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 Direct Transposition of the GloBE Rules: Different Approaches By Switzerland & New Zealand
Norway	Norway: GloBE Country Guide	On April 3, 2024, Regulations for the implementation of the GloBE law were issued. On June 19, 2024, the Norwegian Ministry of Finance initiated a consultation on the introduction of the UTPR. On October 7, the Norwegian government issued the proposal to introduce the UTPR. On June 25, 2024, the Norwegian GloBE law was amended. 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 January 12, 2024, Amendments were made to the Tax Administration Act to reflect GloBE filing. 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. See our English Translation	Explanation	Norway GloBE Guide Updated for Amended Regulations Norway Sends its Updated GloBE Law to Parliament Norway Issues Consultation and Draft Law For Pillar 2 Rules
Poland	Poland: GloBE Country Guide	On November 7, 2024 the draft law implementing the EU Minimum Tax Directive in Poland was passed by the upper house of Parliament (with no amendments) and has been passed to the President for enactment. On April 25, 2024, the Polish Ministry of Finance issued a draft law to implement the EU Minimum Tax Directive from January 1, 2025 (with an option to apply the regulations retrospectively from 2024). On September 25, 2024, the draft bill was sent to the Polish Parliament.	Explanatory Notes	Poland to Delay Pillar Two Implementation to 2025
Portugal	Portugal: GloBE Country Guide	On November 8, 2024, the law to transpose the EU Minimum Tax Directive was published in the Official Gazette. On October 30, 2024, the Portuguese President promulgated the law enacting the EU Minimum Tax Directive. On October 22, 2024, Decree No. 13/XVI of the Portuguese Parliament was issued to approve a law to introduce, an Income Inclusion Rule (IIR) and an Undertaxed Profits Rule (UTPR), as well as a Qualified Domestic Minimum Top-up Tax (QDMTT), which allows Portugal to collect top-up taxes on low-taxed Portuguese entities of both foreign and domestic groups. The law applies for tax years beginning on or after 1 January 2024 for the IIR and QDMTT, and tax years beginning on or after 1 January 2025 for the UTPR. On September 11, 2024, the Portuguese Council of Ministers approved a law to implement the EU Minimum Tax Directive into domestic law. 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.	–	Portugal Approves Pillar 2 Law, Bahamas and Cyprus Table Legislation in Parliament
Romania	Romania: GloBE Country Guide	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. See our English Translation	Explanatory Notes	A Review of Romania’s Draft Pillar Two Law
Singapore	Singapore: GloBE Country	On October 15, 2024, Singapore’s Parliament passed the Multinational Enterprise (Minimum Tax) Bill which includes a multinational top-up tax (MTT) and a domestic top-up tax (DTT). On October 4, 2024, Singapore issued a Consultation document on the GloBE Safe Harbours (Transitional Country-by-Country Reporting Safe Harbour, QDMTT Safe Harbour and the Simplified Calculations Safe Harbour). On September 9, 2024, Singapore introduced its Multinational Enterprise (Minimum Tax) Bill, 2024 into Parliament. The Bill is based on the previously issued draft law, with a number of amendments. On June 10, 2024, the Singapore Ministry of Finance issued a draft Multinational Enterprise (Minimum Tax) Bill and subsidiary legislation for consultation. The consultation is open until July 5, 2024.	Explanatory Statement	Singapore Issues Draft Legislation for OECD Safe Harbours
Slovakia	Slovakia: GloBE Country Guide	On September 11, 2024, the government of Slovakia approved a draft bill on amendments to the law to reflect various aspects of the OECD Administrative Guidance. On December 23, 2023, Act No. 507/2023 to implement relevant provisions of the EU Minimum Tax Directive, was published in the Official Gazette. 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’. The draft law was passed by the Legislative Council on December 8, 2023.		Slovakia’s GloBE Law Applies the EU’s IIR/UTPR Postponement Provision
Slovenia	Slovenia: GloBE Country Guide	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.		Slovakia, Slovenia, Croatia and Bulgaria Gazette Pillar Two Laws
South Africa	South Africa: GloBE Country Guide	On October 30, 2024 the Global Minimum Tax Bill and the Global Minimum Tax Administration Bill were sent to the National Assembly. 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 for consultation.	Explanatory Notes	South Africa Country Guide Updated for Latest Draft Laws South Africa Issues a Draft Law to Transpose the OECD GloBE Rules & Adopts an ‘Ambulatory’ Approach
South Korea	South Korea: GloBE Country Guide	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, 2023, Law 19928 was issued to amend the International Tax Adjustment Act. On November 9, 2023, South Korea issued the Preliminary Legislative Notice of Partial Amendment to the Enforcement Decree of the International Tax Mediation Act. 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 July 28, 2023, the South Korean government published the Partial Amendment Proposal for 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 July 22, 2022, South Korea released a draft law to implement Pillar Two. See our English Translations		South Korea’s 2024 Tax Law Amendment Bill Includes Pillar 2 Updates 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	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		Spain Opens a Consultation on the Global Minimum Tax
Sweden	Sweden: GloBE Country Guide	On October 15, 2024, the Swedish government approved a bill amending the country’s global minimum tax legislation. This includes aspects of the OECD Administrative Guidance, including the December 2023 Safe Harbour amendments. 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. See our English Translation	Explanatory Notes 1 Explanatory Notes 2	Sweden Issues Proposed Draft Legislation to Implement OECD Administrative Guidance Review of the Draft Swedish Global Minimum Tax Law
Switzerland	Switzerland: GloBE Country Guide	On September 4, 2024, the Swiss Federal Council announced that the IIR is to apply from January 1, 2025. 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. See our English Translation	Explanation	Switzerland Applies IIR From January 1, 2025 Switzerland Issues Second Consultation on the GloBE Rules Direct Transposition of the GloBE Rules: Different Approaches By Switzerland & New Zealand Analysis of Switzerlands Draft Pillar Two Decree Direct Transposition of the GloBE Rules: Different Approaches By Switzerland & New Zealand Switzerland Issues Second Consultation on the GloBE Rules
Thailand	Thailand: GloBE Country Guide	On March 1, 2024, the Thai Revenue Department published an 18-page consultation paper on the implementation of Pillar Two. This includes draft legislation which includes, an IIR, UTPR and a domestic minimum tax.		Thailand Issues Draft Pillar Two Legislation
The Netherlands	Netherlands: GloBE Country Guide	On September 17, 2024, a draft law to amend the Minimum Tax Act was published. This includes a number of amendments to implement the OECD Administrative Guidance. On October 3, 2024, a further amendment to the draft law was published. 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 December 19, 2023, the Dutch Senate approved 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 Netherlands presented the Minimum Tax Bill, 2024 to Parliament on May 31, 2023. See our English Translation	Memorandum of Amendment to to Minimum Tax Act	The Netherlands Issues GloBE Amendments for OECD Administrative Guidance The Netherlands Sends GloBE Minimum Tax Act to Parliament Key Takeaways From the Dutch Draft Pillar Two Legislation
The United Kingdom	United Kingdom: GloBE Country Guide	On November 7, 2024, the Finance Bill 2024-2025 was introduced to Parliament. This includes provisions to enact the UTPR (and associated rules such as the Transitional UTPR Safe Harbour and Initial Phase of International Activity Exemption), and other Pillar 2 amendments. In the UK 2024 Budget on October 30, 2024, it was confirmed that: • The UTPR is to apply from 2025 • The transitional CbCR anti-arbitrage rules are to be implemented (effective from the publication of the Written Ministerial Statement on March 14, 2024). Other amendments are also to be made to the MTT and DTT regime for technical changes and to provide for the Fourth Set of OECD Administrative Guidance. On September 12, 2024, the UK issued further draft guidance on the Multinational Top-up Tax and Domestic Top-up Tax. The issued draft guidance now runs to over 300 pages. On July 29, 2024, the UK government issued Draft Legislation for the Hybrid Arbitrage Arrangement Anti-Avoidance Rule On July 18, 2024, the UK issued draft legislation to implement the UTPR. 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 UK 2024 Finance Act received royal assent. This domestically implements amendments provided in the OECD Administrative Guidance. On December 21, 2023, the UK issued detailed draft guidance on various aspects of the UK’s multinational top-up tax, including how to calculate the ETR. Finance (No. 2) Act for the ‘Multinational Top-Up Tax‘ enacted on July 11, 2023. On June 15, 2023, the UK issued draft guidance on the application of the multinational top-up tax.	Explanatory Notes to the 2024-2025 Finance Bill Draft Guidance – September 2024 Draft Guidance Notes	Review of the Pillar 2 Provisions in the UK Finance Bill 2024-2025 UK Issues Draft Legislation for the Hybrid Arbitrage Anti-Avoidance Rule 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 UK Proposes Amendments to Global Minimum Tax Rules
Turkey	Turkey: GloBE Country Guide	The “Law on the Amendment of Tax Laws and Certain Laws” was published in the Turkish Official Gazette on August 2, 2024. Articles 37 – 50 of the Law include provisions to implement the GloBE rules in domestic law from January 1, 2024. This includes the IIR, UTPR (from 2025) and a domestic minimum top-up tax.	–	Turkey Enacts its Pillar Two Law Turkey Gazettes Pillar 2 IASB Amendments
Vietnam	Vietnam: GloBE Country Guide	On November 12, 2024, the Vietnamese Ministry of Finance released a draft Decree on the implementation of Resolution No. 107/2023/QH15 on the Global Minimum Tax. The draft decree provides for the detailed application of the GloBE rules in Vietnam. 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		Vietnamese Parliament Approves QDMTT From 2024 Vietnam Issues Draft Pillar 2 Resolution

Map: Pillar Two Implementation

Analysis

Country	Status	IIR	UTPR	QDMTT	Analysis
African Tax Administration Forum (ATAF)	Draft Legislation	N/A	N/A	Yes	ATAF Releases Domestic Minimum Tax Legislation
Argentina	Planned for 2024 Budget package	Awaiting Details	Awaiting Details	Awaiting Details	See our Pillar Two Developments Tracker
Australia	Draft Legislation/ Consultation (See our English Translation) See: Australia: GloBE Country Guide	January 1, 2024	January 1, 2025	January 1, 2024	Australia Submits Pillar 2 Laws to Parliament A Review of Australia’s Draft Pillar Two Legislation Australia Issues Update on Global Minimum Tax Australian Budget Confirms 2024 GloBE Implementation Australia’s Consultation on Pillar Two See our Pillar Two Developments Tracker
Austria	Enacted Legislation (See our English Translation) See: Austria: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Austria Updates Minimum Tax Act for Aspects of OECD Administrative Guidance A Review of Austria’s Draft Pillar Two Law
Bahamas	Draft Legislation See: Bahamas: GloBE Country Guide	No	No	January 1, 2025 (unless the Group or any of its Constituent Entities is subject to an IIR or UTPR in another jurisdiction in respect of that Fiscal Year)	GloBE Country Guide: The Bahamas The Bahamas Issues a Policy Paper on a New CIT System, Including a QDMTT The Bahamas & Cayman Islands Approach To The Global Minimum tax See our Pillar Two Developments Tracker
Bahrain	Draft Legislation (See our English Translation) See: Bahrain: GloBE Country Guide	No	No	January 1, 2025	GloBE Country Guide: Bahrain
Barbados	Draft Legislation See: Barbados: GloBE Country Guide	No	No	January 1, 2024	GloBE Country Guide: Barbados Bermuda and Barbados Announce GloBE Implementation Barbados 2023 Budget Confirms Global Minimum Tax Proposals Are In Progress
Belgium	Enacted Legislation (See our English Translation) See: Belgium: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Belgium Issues a Draft 7 Page QDMTT Return for Consultation Belgium Extends Registration Deadline to September 16, 2024 if no 2024 GMT Advance Payments Belgian Royal Decree Sets July 13, 2024 as the Deadline for the First GloBE Notification Form Belgium’s Pillar Two Notification Form Requires Significant Data Input Belgium Issues Draft Law to Implement the OECD Administrative Guidance A Review of Belgium’s Draft Pillar Two Law
Bermuda	Enacted Legislation	No	No	No	Bermuda Issues Draft Corporate Income Tax Law Bermuda and Barbados Announce GloBE Implementation Bermuda Announces 2024 Global Minimum Tax in 2023 Throne Speech Bermuda Issues Consultation for a Corporate Income Tax Bermuda’s Plans For a Global Minimum Tax
Brazil	Enacted Law See: Brazil: GloBE Country Guide	No	No	January 1, 2025	Brazil Implements a QDMTT From January 1, 2025 Brazil Planning 15% Global Minimum Tax Implementation OECD Recommends Global Minimum Tax is Included in Brazil’s Tax Reform
British Virgin Islands (BVI)	Commentary	N/A	N/A	N/A	The BVI is Taking a Different Approach to the Bahamas for Pillar 2
Bulgaria	Enacted Legislation (See our English Translation) See: Bulgaria: GloBE Country Guide	January 1, 2024	January 1, 2025	January 1, 2024	Bulgaria Issues a Draft Law to Provide for OECD Administrative Guidance, Including the UTPR Safe Harbour A Review of Bulgaria’s Draft Pillar Two Law
Canada	Enacted Legislation See: Canada: GloBE Country Guide	December 31, 2023	Draft Law (December 31, 2024)	December 31, 2023	Canada Issues Explanatory Notes on the Global Minimum Tax A Review of Canada’s Draft GloBE Law
Cayman Islands	Commentary	N/A	N/A	N/A	See our Pillar Two Developments Tracker
China	Commentary	N/A	N/A	N/A	Chinese Developments in Global Minimum Tax Implementation A Review of China’s Tax Law From a Pillar Two Perspective
Croatia	Enacted Legislation See: Croatia: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	See our Pillar Two Developments Tracker
Curacao	Draft Legislation	January 1, 2025	No	January 1, 2025
Cyprus	Draft Legislation (See our English Translation) See: Cyprus: GloBE Country Guide	December 31, 2023	December 31, 2024	January 1, 2025	Portugal Approves Pillar 2 Law, Bahamas and Cyprus Table Legislation in Parliament EU Gives Spain, Cyprus, Latvia, Lithuania, Poland and Portugal 2 Months to Enact Domestic Pillar 2 Laws EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2 A Review of Cyprus’s Draft Pillar Two Law
Czech Republic	Enacted Legislation (See our English Translation) See: Czech Republic: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Czech Republic Amends Draft Law Amending its GloBE Law A Review of the Czech Draft Top-Up Tax Act GloBE Country Guide: Czech Republic
Denmark	Enacted Legislation See: Denmark: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Denmark GloBE Country Guide: Updated for June 2024 Amending Law A Review of the Danish Draft Minimum Tax Act Danish Tax Authority Issues MNEs a Questionnaire for the GloBE Information Return
Estonia	Enacted Legislation See: Estonia: GloBE Country Guide	Art. 50 Postponement to December 31, 2029	Art. 50 Postponement to December 31, 2029	No	Estonia Issues Draft Pillar 2 Law Including Art. 50 Postponement EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2 See our Pillar Two Developments Tracker Pillar Two GloBE Rules and Estonia’s Distribution Tax
European Union	Enacted	December 31, 2023	December 31, 2024	Left to Individual EU Jurisdictions	EU Issues DAC 9 Proposal for Centralised GIR Filing Within the EU The New Zealand and EU Approaches to the Domestic Income Inclusion Rule (DIIR) EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2 EU Issues Commission Notice For Jurisdictions Delaying the IIR/UTPR Mapping the Model Rules to the EU Global Minimum Tax Directive Full Steam Ahead For EU Pillar Two Implementation Review of the Draft EU Pillar Two Directive
Finland	Enacted Legislation (See our English Translation) See: Finland: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Finland Issues Draft Pillar 2 Amendment Law to Reflect OECD Administrative Guidance Key Aspects of Finland’s Draft GloBE Law
France	Enacted Legislation (See our English Translation) See: France: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	France GloBE Country Guide Updated for the 2025 Finance Bill A Review of France’s Draft Pillar Two Law
Germany	Enacted Legislation (See our English Translation) See: Germany: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	German MoF Issues Draft Law for AG3 Provisions Including Transitional CbCR and Blended CFC Rules Germany Releases its Group Parent Notification Form for German Minimum Tax Groups Germany Includes an Amendment to its GMT Law in the Draft Annual Tax Act Germany Issues Draft GMT Return For Feedback Germany Approves and Updates its GloBE Law Amendments to Germany’s Pillar 2 Regime in the Updated Draft Law GloBE Country Guide: Germany Germany Publishes Draft Global Minimum Tax Legislation German Proposals Include a Pillar Two Whitelist
Gibraltar	Proposal	January 1, 2025	Awaiting Details	December 31, 2023	Gibraltar 2024 Budget Confirms QDMTT Introduction See our Pillar Two Developments Tracker
Greece	Enacted Legislation See: Greece: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Greece Enacts Pillar Two Law A Review of Greece’s Draft Pillar Two Law EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2 See our Pillar Two Developments Tracker
Guernsey	Proposal	January 1, 2025	No	January 1, 2025	Guernsey, Jersey and the Isle of Man Announce a Global Minimum Tax From 2025
Hong Kong	Consultation/drafting legislation	January 1, 2025	Deferred to a later date	January 1, 2025	Hong Kong Issues Outcome of the Consultation on the Introduction of the GloBE Rules Hong Kong to Implement Global Minimum Tax in 2025 See our Pillar Two Developments Tracker
Hungary	Enacted Law (See our English Translation) See: Hungary: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Hungary Includes GloBE Amendments in its 2024 Autumn Tax Proposal Hungary Becomes The First EU Member To Enact Pillar 2 Law Hungary Approves and Updates its GloBE Law A Review of Hungary’s Draft Pillar Two Law Hungary’s Prime Minister Reiterates the Local Business Tax is a Covered Tax for GloBE Purposes
Iceland	Consultation	January 1, 2025	Awaiting Details	January 1, 2025	–
India	Commentary	Awaiting Details	Awaiting Details	Awaiting Details	India’s Tax Regime after Pillar Two: Key Risks and Opportunities
Indonesia	Partial Enactment	Awaiting Details	Awaiting Details	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	Enacted Legislation See: Ireland: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Ireland GloBE Country Guide Updated for the 2024 Finance Bill 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 Irish 2022 Finance Bill Changes for Pillar Two
Isle of Man	Draft Law See: Isle of Man: GloBE Country Guide	January 1, 2025	No	January 1, 2025	Isle of Man Issues Draft Legislation for the IIR and QDMTT from 2025 Isle of Man Announces QDMTT From 2025 Guernsey, Jersey and the Isle of Man Announce a Global Minimum Tax From 2025
Israel	Announcement	No	No	January 1, 2026	Israel to Apply a QDMTT from 2026 Israel Reaffirms Pillar Two Implementation Key Risks for MNEs Operating in Israel after Pillar Two
Italy	Enacted Legislation (See our English Translation) See: Italy: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Italy Issues SBIE Decree to Implement the July 2023 and June 2024 OECD Administrative Guidance Detailed Analysis of the Italian QDMTT Implementing Decree Italy Issues a Decree for the Transitional CbCR & UTPR Safe Harbours A Review of Italy’s Draft Pillar Two Law
Jamaica	Proposal	No	No	Awaiting Details (Planned Transposition from the OECD Model Rules)	See our Pillar Two Developments Tracker
Japan	Enacted Law (See our English Translation) See: Japan: GloBE Country Guide	April 1, 2024	No	Being Considered for 2025	Japan Issues Circular for Additional GloBE Guidance What Japan’s Cabinet Order on Pillar 2 Includes & Doesn’t Include Overview of Japan’s Latest Ministerial Ordinance on Pillar 2 GloBE Country Guide: Japan Overview of Japan’s Cabinet Order on the Global Minimum Tax Japan’s Global Minimum Tax Law Is Enacted See our Pillar Two Developments Tracker Japans Pillar 2 Proposals in its 2023 Tax Reform Outline Japan Submits Draft Pillar Two Law to Parliament Japan’s Accounting Standards Board Publishes Deferred Tax Guidance For Global Minimum Tax Sourcing the Japanese Pillar Two Law to the OECD Model Rules
Jersey	Enacted Law See: Jersey: GloBE Country Guide	January 1, 2025	No	No	Jersey GloBE Guide Updated for Final Enacted Law Jersey to implement an IIR and DMT from January 1, 2025 Guernsey, Jersey and the Isle of Man Announce a Global Minimum Tax From 2025 Jerseys approach to Pillar Two implementation
Kenya	Draft Legislation	No	No	January 1, 2025	Kenya Includes a Domestic Minimum Tax in its 2024 Finance Bill See our Pillar Two Developments Tracker
Kuwait	Commentary	Awaiting Details	Awaiting Details	Awaiting Details	Kuwait Considers Pillar Two Application IMF Recommends Extension of Kuwait’s CIT For GloBE Implementation
Latvia	Enacted Legislation See: Latvia: GloBE Country Guide	Art. 50 Postponement to December 31, 2029	Art. 50 Postponement to December 31, 2029	No	Latvian Parliament Adopts Law to Implement EU Minimum Tax Directive EU Gives Spain, Cyprus, Latvia, Lithuania, Poland and Portugal 2 Months to Enact Domestic Pillar 2 Laws Latvia Issues Draft Pillar Two Law & Confirms Postponement EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2
Liechtenstein	Enacted Legislation (See our English Translation) See: Liechtenstein: GloBE Country Guide	January 1, 2024	January 1, 2025	January 1, 2024	A Review of the Liechtenstein GloBE Regulation Liechtenstein Publishes Draft Global Minimum Tax Law
Lithuania	Enacted Legislation (See our English Translation) See: Lithuania: GloBE Country Guide	Art. 50 Postponement to December 31, 2029 (draft law to apply an IIR from January 1, 2025)	Art. 50 Postponement to December 31, 2029 (draft law to apply a UTPR from January 1, 2025)	No (draft law to apply a QDMTT from January 1, 2025)	Lithuania GloBE Country Guide Updated for Latest Draft Law EU Gives Spain, Cyprus, Latvia, Lithuania, Poland and Portugal 2 Months to Enact Domestic Pillar 2 Laws EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2 Lithuania Issues Draft Pillar Two Law & Confirms Postponement
Luxembourg	Enacted Legislation (See our English Translation) See: Luxembourg: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Luxembourg GloBE Guide Updated for October 2024 Amendments to Draft Law Luxembourg Government Approves Draft Law to Include Additional OECD Administrative Guidance Luxembourg Updates its Draft GloBE Law for OECD Administrative Guidance Key Aspects of the Luxembourg Draft GloBE Law Luxembourg Government Approves Pillar Two Bill Luxembourg Private Debt Funds and Pillar Two
Malaysia	Enacted Legislation See: Malaysia: GloBE Country Guide	January 1, 2025	No	January 1, 2025	GloBE Country Guide: Malaysia A Review of Malaysia’s Draft Pillar Two Law Malaysia’s 2024 Budget Proposes GloBE Implementation from 2025 Today’s Malaysian 2023 Revised Budget Stands by 2024 Global Minimum Tax Malaysia to Implement Global Minimum Tax & QDMTT in 2024
Malta	Enacted Legislation See: Malta: GloBE Country Guide	Art. 50 Postponement to December 31, 2029	Art. 50 Postponement to December 31, 2029	No	Malta Enacts EU Minimum Tax Directive With Art. 50 Postponement EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2 See our Pillar Two Developments Tracker
Mauritius	Partial Enactment	No	No	Included in Finance Act – Awaiting Details	Mauritius 2022 Finance Act includes Pillar Two Top-Up Tax
Mexico	Working Group	Awaiting Details	Awaiting Details	Awaiting Details	See our Pillar Two Developments Tracker
New Zealand	Enacted Legislation See: New Zealand: GloBE Country Guide	January 1, 2025	January 1, 2025	No (But a domestic IIR from January 1, 2026)	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 New Zealand’s Approach to Pillar Two Direct Transposition of the GloBE Rules: Different Approaches By Switzerland & New Zealand
Nigeria	Rejected	No	No	No	Nigeria Reconsidering Its Approach To Pillar Two The Impact of Nigeria’s Rejection of Both Pillar 1 and 2
Norway	Enacted Law (See our English Translation) See: Norway: GloBE Country Guide	January 1, 2024	No (proposed in 2024 Budget to apply from 2025)	January 1, 2024	Norway GloBE Guide Updated for Amended Regulations Norway Sends its Updated GloBE Law to Parliament Norway Issues Consultation and Draft Law For Pillar 2 Rules
Oman	Commentary	Awaiting Details	Awaiting Details	Awaiting Details	Oman’s Tax Regime and Pillar Two
Paraguay	Working Group	Awaiting Details	Awaiting Details	Awaiting Details	See our Pillar Two Developments Tracker Paraguay’s Significant Pillar Two Risk
Philippines	Commentary	Awaiting Details	Awaiting Details	Awaiting Details	The Philippines Tax Regime and the Pillar Two GloBE Rules
Poland	Draft Law See: Poland: GloBE Country Guide	January 1, 2025	January 1, 2025	January 1, 2025	GloBE Country Guide: Poland Poland to Delay Pillar Two Implementation to 2025 EU Gives Spain, Cyprus, Latvia, Lithuania, Poland and Portugal 2 Months to Enact Domestic Pillar 2 Laws EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2 Delays in Poland’s Domestic Legislation
Portugal	Enacted Legislation See: Portugal: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	GloBE Country Guide: Portugal EU Gives Spain, Cyprus, Latvia, Lithuania, Poland and Portugal 2 Months to Enact Domestic Pillar 2 Laws EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2
Puerto Rico	Consultation	–	–	–
Qatar	Drafting a QDMTT	Awaiting Details	Awaiting Details	Awaiting Details	See our Pillar Two Developments Tracker
Romania	Enacted Legislation (See our English Translation) See: Romania: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	GloBE Country Guide: Romania A Review of Romania’s Draft Pillar Two Law
Singapore	Draft Legislation See: Singapore: GloBE Country Guide	January 1, 2025	No	January 1, 2025	Singapore Issues Draft Legislation for OECD Safe Harbours Singapore Introduces its Draft GloBE Law to Parliament Singapore To Implement Pillar Two From 2025 A Pillar Two Review of Singapore’s Tax System
Slovakia	Enacted Legislation (See our English Translation) See: Slovakia: GloBE Country Guide	Art. 50 Postponement to December 31, 2029	Art. 50 Postponement to December 31, 2029	December 31, 2023	Slovakia’s GloBE Law Applies the EU’s IIR/UTPR Postponement Provision See our Pillar Two Developments Tracker Slovakia Issues Draft Pillar Two Law
Slovenia	Enacted Legislation See: Slovenia: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	GloBE Country Guide: Slovenia
South Africa	Draft Legislation See: South Africa: GloBE Country Guide	January 1, 2024	No	January 1, 2024	South Africa Country Guide Updated for Latest Draft Laws GloBE Country Guide: South Africa South Africa Issues a Draft Law to Transpose the OECD GloBE Rules & Adopts an ‘Ambulatory’ Approach South Africa Issues Draft Global Minimum Tax Bill South Africa Confirms Global Minimum Tax In 2024 Taxation Laws Amendment Bill
South Korea	Enacted Law (See our English Translation) See: South Korea: GloBE Country Guide	January 1, 2024	January 1, 2025	No	A Review of South Korea’s Pillar Two Amendments to its Enforcement Regulation South Korea Releases Pillar Two Forms, Including GloBE Information Return & GloBE Tax Return A Review of South Korea’s Latest GloBE Amendments South Korea Issues Draft Pillar 2 Amendment Law Sourcing the South Korean Pillar Two Law to the OECD Model Rules 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	Draft Legislation (See our English Translation) See: Spain: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Spanish Parliament Publishes Draft GMT Law EU Gives Spain, Cyprus, Latvia, Lithuania, Poland and Portugal 2 Months to Enact Domestic Pillar 2 Laws EU Commission Issues Infringement Decisions Against 9 Member States For Not Enacting Pillar 2 Spain Issues Draft Pillar Two Legislation Spain Opens a Consultation on the Global Minimum Tax
Sweden	Enacted Legislation (See our English Translation) See: Sweden: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	Sweden Issues Proposed Draft Legislation to Implement OECD Administrative Guidance GloBE Country Guide: Sweden Review of the Draft Swedish Global Minimum Tax Law English Translation of the Swedish Draft Global Minimum Tax Law
Switzerland	Enacted Legislation & Constitutional Amendment (See our English Translation) See: Switzerland: GloBE Country Guide	January 1, 2025	No	January 1, 2024	GloBE Country Guide: Switzerland Switzerland Applies IIR From January 1, 2025 Switzerland Issues Report on Cantonal Pillar 2 Developments Swiss Referendum Approves 2024 Global Minimum Tax Switzerland Issues Second Consultation on the GloBE Rules GloBE Country Guide: Switzerland Analysis of Switzerland’s Draft Pillar Two Decree Switzerland Approves the GloBE Rules Direct Transposition of the GloBE Rules: Different Approaches By Switzerland & New Zealand
Taiwan	No Legislative Schedule Provided	Awaiting Details	Awaiting Details	Awaiting Details	Taiwan’s Ministry of Finance Confirms No Timeline for Pillar 2 Implementation A Pillar Two Review of Taiwan’s Tax Regime Taiwan To Increase Its Domestic Minimum Tax Rate From 2024
Thailand	Draft Legislation See: Thailand: GloBE Country Guide	January 1, 2025	January 1, 2025	January 1, 2025	GloBE Country Guide: Thailand Thai Cabinet Approves Global Minimum Tax Proposal Thailand’s Tax Incentive Regime and Pillar Two
The Netherlands	Enacted Legislation (See our English Translation) See: The Netherlands: GloBE Country Guide	December 31, 2023	December 31, 2024	December 31, 2023	The Netherlands Issues GloBE Amendments for OECD Administrative Guidance The Netherlands Sends GloBE Minimum Tax Act to Parliament GloBE Country Guide: The Netherlands Key Takeaways From the Dutch Draft Pillar Two Legislation
Turkey	Enacted Legislation See: Turkey: GloBE Country Guide	January 1, 2024	January 1, 2025	January 1, 2024	Turkey Gazettes Pillar 2 IASB Amendments
UAE	Consultation + High Level Amendments to CIT Law	Not in 2024	Not in 2024	Not in 2024	A Review of the UAE Consultation on the Introduction of the GloBE Rules See our Pillar Two Developments Tracker UAEs New Corporate Tax Law and Pillar Two
United Kingdom	IIR/QDMTT: Enacted Law UTPR: Proposed in the 2024-2025 Finance Bill See: The UK: GloBE Country Guide	31 December 2023	31 December 2024 (confirmed in the 2024-2025 Finance Bill)	31 December 2023	Review of the Pillar 2 Provisions in the UK Finance Bill 2024-2025 UK Issues Further Draft Pillar 2 Guidance UK to Apply Transitional CbCR Safe Harbour Anti-Avoidance Rule From March 14, 2024 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 Key Differences in Excluded Entities Between OECD Model Rules & UK Draft Legislation Review of the UK Global Minimum Tax in Yesterday’s 2023 Spring Finance Bill 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 UK Proposes Amendments to Global Minimum Tax Rules A Review of the UK QDMTT and the OECD Administrative Guidance
United States	Commentary	No	No	No	U.S Updates its GloBE Impact Document See our Pillar Two Developments Tracker
Vietnam	Resolution Enacted See: Vietnam: GloBE Country Guide	January 1, 2024	No	January 1, 2024	See our Pillar Two Developments Tracker Vietnam Issues Draft Pillar 2 Resolution 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
Zimbabwe	Legislation enacted	No	No	Domestic minimum tax

Lee Hadnum

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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Vietnam Issues a Draft Decree for Detailed GloBE Provisions

Netherlands GloBE Country Guide Updated for Latest Amended Draft Law

UK GloBE Guide Updated for Finance Bill 2024-2025

South Africa Country Guide Updated for Latest Draft Laws