Poland Issues a List of Jurisdictions that Have Qualified IIRs and DMTTs for Pillar 2

Article 125 of the Polish Global Minimum Tax Law provides for the application of the QDMTT Safe Harbour. It provides that the Ministry of Finance will publish a list of jurisdictions that have implemented a QDMTT that qualifies for the Safe Harbour in the Official Gazette.

On February 12, 2025, the Polish Minster of Finance published in the Official Gazette a list of jurisdictions that have qualified status for the purposes of the income inclusion rule (IIR) and domestic minimum tax (DMTT), including the QDMTT Safe Harbour. 

The list of jurisdictions with qualifying status applies as at February 7, 2025, however, it does not yet include a number of jurisdictions that have IIRs and DMTTs in place (and which were enacted late in 2024 or early 2025).  

The list follows the same approach as the list of jurisdictions with Transitional Qualified Status published by the OECD on January 15, 2025.

Jurisdictions that Qualify (and Don’t Qualify) Currently for Transitional Qualified Status

The table below indicates:

-which jurisdictions have an IIR or DMTT;

-the effective date of implementation;

-whether the IIR and DMTT qualify for Qualified Status under the Polish List;

-if there is a QDMTT, whether that qualifies for the QDMTT Safe Harbour.