The OECD’s Pillar Two framework aims to ensure that MNEs with global revenues exceeding EUR 750 million pay a minimum effective tax rate on income arising in each jurisdiction in which they operate. The framework imposes a top-up tax on profits arising in jurisdictions where the effective tax rate (ETR) is below 15%.
The core elements of Pillar Two are an income inclusion rule (IIR) and an Undertaxed Profits Rule (UTPR).
A country may also elect to implement a Qualified Domestic Minimum Top-up Tax (QDMTT. The timing of implementation for each element varies by territory.
The following tracker indicates the current status of the implementation of the Pillar Two rules around the world.