BDO's Pillar Two Map tracks the implementation of the OECD's Pillar Two global minimum tax across jurisdictions. Pillar Two is designed to ensure that multinational enterprises (MNEs) with consolidated annual revenues exceeding €750 million are subject to a minimum effective tax rate of 15% in every jurisdiction where they operate. Where the effective tax rate (ETR) in a jurisdiction falls below this threshold, a top-up tax may arise to bring the overall taxation of those profits up to the minimum level.
The OECD Pillar Two framework is primarily implemented through two key mechanisms:
- Income Inclusion Rule (IIR)
- Undertaxed Profits Rule (UTPR)
Many jurisdictions have also introduced Qualified Domestic Minimum Top-up Tax (QDMTT), enabling them to collect top-up tax locally rather than allowing taxing rights to be exercised elsewhere.
As countries continue to adopt and implement Pillar Two legislation, the status of the rules varies significantly across jurisdictions. Many countries have enacted legislation, while others are progressing through consultation, draft legislation, or early-stage policy development.
Our Pillar Two map tracks the implementation of Pillar Two across the jurisdictions participating in the OECD Inclusive Framework. The map enables businesses, tax professionals and multinational groups to monitor legislative developments, compare country positions, and stay informed about the evolving global minimum tax landscape
