Pillar Two


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 chart summarises the implementation status of countries that are part of the OECD Inclusive Framework and that have agreed to adopt the global minimum tax and taken steps towards introducing the Pillar Two rules.

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Inclusive Framework countries that have not  made any announcements will not be included in the chart unless and until they have taken an official position on Pillar Two.

This tracker has been carefully prepared and is being regularly updated with best efforts as per the date indicated above, but it has been written in general terms and should be seen as containing broad statements only. This tracker should not be used or relied upon to cover specific situations and you should not act, or refrain from acting, upon the information contained in it. Hyperlinks included in the charts may link to websites maintained and operated by third parties over which BDO has no control. BDO does not make any representations about the accuracy or other facets of information posted on this or other websites. Please refer to our full legal disclaimer for more information.