Last Updated: September 12, 2023
| Country | GloBE Country Guide | Legislation | Substantive Enactment | Analysis |
|---|---|---|---|---|
| Canada | Canada: GloBE Country Guide | On August 4, 2023, Canada issued the draft Global Minimum Tax Act for consultation. | No (When tabled for first reading if there is a majority government, otherwise after the third reading) | A Review of Canada’s Draft GloBE Law |
| Czech Republic | Czech Republic | On August 16, 2023, the Czech Cabinet approved the draft top-up tax act. | No (Signature of the President required) | A Review of the Czech Draft Top-Up Tax Act |
| Denmark | Denmark: GloBE Country Guide | On June 23, 2023, the Danish Ministry of Taxation issued the draft Minimum Tax Act (the ‘Bill’) to give effect to the GloBE rules. | No (After the second reading in Parliament) | A Review of the Danish Draft Minimum Tax Act |
| EU | – | 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. | – | 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 | – | On August 15, 2023, the Finnish Ministry of Finance issued a draft law for the implementation of the EU Global Minimum Tax Directive. | No (Approval of Parliament required) | Key Aspects of Finland’s Draft GloBE Law |
| Germany | Germany | 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. | No (Approval by the Upper and Lower Houses of Parliament required) | Amendments to Germany’s Pillar 2 Regime in the Updated Draft Law Germany Publishes Draft Global Minimum Tax Legislation |
| Indonesia | – | On December 20, 2022, Indonesia issued Government Regulation No. 55/2022 on the Adjustment of Regulations in the Field of Income Tax. This included reference to the implementation of a global minimum tax in Indonesia as well a a desire to implement Pillar One. | No (Approval by the President and Parliament given but awaiting detailed regulations) | Indonesian Regulation Signals Global Minimum Tax Implementation |
| Ireland | Ireland | 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. | No (Approval by the House of Representatives required) | Ireland Issues Second Feedback Statement on Pillar Two Ireland Issues Draft Global Minimum Tax Law For Feedback |
| Italy | – | 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’). | No (Signature of the President required) | A Review of Italy’s Draft Pillar Two Law |
| Japan | Japan | 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 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. | Yes (Approved by the Diet) | 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 |
| Liechtenstein | Liechtenstein | On March 29, 2023, Liechtenstein published draft legislation for the implementation of the Pillar Two Globe Rules. | No (Parliamentary approval required) | Liechtenstein Publishes Draft Global Minimum Tax Law |
| Luxembourg | GloBE Country Guide: Luxembourg | On 4 August 2023, the Luxembourg government issued Draft Law No. 8292 to implement the EU Minimum Tax Directive. | No (Ratfication by the Grand-Duc required) | Key Aspects of Luxembourg’s Draft GloBE Law |
| Mauritius | – | The Finance (Miscellaneous Provisions) Act 2022 which implements provisions of the 2022 Budget in Mauritius includes mention of a qualified domestic minimum tax for Pillar Two purposes. | No (Presidential assent given but detailed regulations required) | Mauritius 2022 Finance Act includes Pillar Two Top-Up Tax |
| New Zealand | New Zealand | 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. | No (After the Third reading in Parliament) | New Zealand Issues Draft Global Minimum Tax Law Direct Transposition of the GloBE Rules: Different Approaches By Switzerland & New Zealand |
| Norway | Norway | 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. | No (Approval of Parliament required) | Norway Issues Consultation and Draft Law For Pillar 2 Rules |
| South Korea | South Korea | 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. | Yes (Presidential promulgation) | 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 |
| Sweden | Sweden | On February 7, 2023, the Special Investigator submitted the interim report on the proposal for the implementation of the Global Minimum Tax Directive to the government. This includes outline draft legislation which mainly corresponds to the EU directive but is adapted to Swedish conditions. | No (Approval by Parliament required) | See our Review of the Draft Swedish Global Minimum Tax Law |
| Switzerland | Switzerland | 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. | No (Approval by Parliament required) | 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 |
| The Netherlands | Netherlands | The Netherlands presented the Minimum Tax Bill, 2024 to Parliament on May 31, 2023. | No (Approval of both Houses of Parliament required) | The Netherlands Sends GloBE Minimum Tax Act to Parliament Key Takeaways From the Dutch Draft Pillar Two Legislation |
| The United Kingdom | United Kingdom | 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. On July 18, 2023, the UK issued draft legislation for the UTPR. | Yes (after the Third Reading in the House of Commons) | 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 |
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