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. 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.