OECD Pillar Two: Global Minimum Tax Tracker
Pillar Two is the OECD's initiative to impose a 15% minimum corporate income tax on multinationals globally. Enacted by most EU countries, the UK, Japan, South Korea, and Switzerland. The US has not yet enacted compliant legislation.
Status by Country
| Country | Status | Effective Date | Notes |
|---|---|---|---|
| 🇦🇺 Australia | enacted | 2024-01-01 | QDMTT enacted |
| 🇦🇹 Austria | enacted | 2024-01-01 | Full Pillar Two rules enacted |
| 🇧🇪 Belgium | enacted | 2024-01-01 | QDMTT + IIR enacted |
| 🇨🇿 Czechia | enacted | 2024-01-01 | IIR + UTPR + QDMTT enacted |
| 🇩🇰 Denmark | enacted | 2024-01-01 | Full implementation |
| 🇪🇪 Estonia | enacted | 2024-01-01 | EU Directive transposition |
| 🇫🇮 Finland | enacted | 2024-01-01 | Full transposition of EU Directive |
| 🇫🇷 France | enacted | 2024-01-01 | IIR + QDMTT + UTPR |
| 🇩🇪 Germany | enacted | 2024-01-01 | Full implementation in force |
| 🇬🇷 Greece | enacted | 2024-01-01 | EU Directive transposition |
| 🇭🇺 Hungary | enacted | 2024-01-01 | QDMTT enacted; IIR/UTPR deferred |
| 🇮🇪 Ireland | enacted | 2024-01-01 | IIR + QDMTT + UTPR enacted |
| 🇮🇹 Italy | enacted | 2024-01-01 | Full transposition |
| 🇯🇵 Japan | enacted | 2024-04-01 | Qualified Domestic Minimum Top-up Tax |
| 🇱🇻 Latvia | enacted | 2024-01-01 | EU Directive transposition |
| 🇱🇹 Lithuania | enacted | 2024-01-01 | EU Directive transposition |
| 🇱🇺 Luxembourg | enacted | 2024-01-01 | IIR + UTPR + QDMTT |
| 🇳🇱 Netherlands | enacted | 2024-01-01 | Full implementation in force |
| 🇳🇿 New Zealand | enacted | 2025-01-01 | QDMTT effective 2025 |
| 🇳🇴 Norway | enacted | 2024-01-01 | IIR + QDMTT enacted |
| 🇵🇱 Poland | enacted | 2025-01-01 | Delayed to 2025 |
| 🇵🇹 Portugal | enacted | 2024-01-01 | EU Directive transposition |
| 🇸🇰 Slovakia | enacted | 2024-01-01 | EU Directive transposition |
| 🇸🇮 Slovenia | enacted | 2024-01-01 | EU Directive transposition |
| 🇰🇷 South Korea | enacted | 2024-01-01 | QDMTT + IIR enacted |
| 🇪🇸 Spain | enacted | 2024-01-01 | IIR + QDMTT enacted |
| 🇸🇪 Sweden | enacted | 2024-01-01 | IIR + UTPR + QDMTT enacted |
| 🇨🇭 Switzerland | enacted | 2024-01-01 | QDMTT via constitutional amendment |
| 🇬🇧 United Kingdom | enacted | 2024-01-01 | Multinational Top-up Tax + DMTT |
| 🇨🇱 Chile | not_started | - | No legislation announced |
| 🇨🇴 Colombia | not_started | - | No legislation announced |
| 🇨🇷 Costa Rica | not_started | - | No legislation announced |
| 🇮🇱 Israel | not_started | - | No specific timeline |
| 🇲🇽 Mexico | not_started | - | Not committed to timeline |
| 🇺🇸 United States | not_started | - | GILTI rules exist but do not fully conform to Pillar Two |
| 🇨🇦 Canada | proposed | - | Announced but legislation delayed |
| 🇮🇸 Iceland | proposed | - | In legislative process |
| 🇹🇷 Turkey | proposed | - | Under consideration |
What Is the Pillar Two Global Minimum Tax?
The OECD/G20 Base Erosion and Profit Shifting (BEPS) Pillar Two framework creates a 15% global minimum corporate income tax for multinationals with over €750 million in annual revenues. It was agreed in October 2021 by 136 countries.
The core rules, the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR), mean that if a multinational pays less than 15% tax in any country, its home country (or other countries in the group) can collect a "top-up tax" to reach the 15% floor.
Most EU member states enacted Pillar Two domestic legislation effective January 2024, following the EU directive. The UK enacted its rules from January 2024. Japan, South Korea, Australia, Canada, and Switzerland have also enacted or begun enacting Pillar Two.
The United States has not enacted GLOBE-compliant legislation. The US has its own GILTI (Global Intangible Low-Taxed Income) rules, but these do not fully comply with the Pillar Two standard, creating ongoing tensions with trading partners.