The new 16 jurisdictions are Brazil, Gibraltar, Indonesia, Isle of Man, Japan, Jersey, Malaysia, New Zealand, North Macedonia, Poland, Portugal, Singapore, South Africa, Switzerland, Thailand, and the UAE.
The OECD/G20 Inclusive Framework on BEPS has updated its “Central Record of Legislation with Transitional Qualified Status” to include Pillar Two provisions for 16 jurisdictions: Brazil, Gibraltar, Indonesia, Isle of Man, Japan, Jersey, Malaysia, New Zealand, North Macedonia, Poland, Portugal, Singapore, South Africa, Switzerland, Thailand, and the UAE.
The complete list of qualified legislation, most recently updated on 18 August 2025, can be accessed on the OECD website.
This update is included in the OECD’s Global Anti-Base Erosion (GloBE) Model Rules as part of Pillar Two.
The GloBE Model Rules consist of an interlocking and coordinated system of rules which are designed to be implemented into the domestic law of each jurisdiction and operate together to ensure large MNE Groups are subject to a minimum effective tax rate of 15% on any excess profits arising in each jurisdiction where they operate. Consistent with the intention of the Inclusive Framework. The GloBE Rules (including the IIR and UTPR) are designed so that the imposition of top-up tax in accordance with those rules will be compatible with the provisions of the United Nations Model Double Taxation Convention between Developed and Developing Countries and the Model Tax Convention on Income and on Capital: Condensed Version 2017, (the OECD Model Tax Convention).
The GloBE Rules rely on jurisdictions having qualified domestic legislation to ensure coordinated tax outcomes, but a full review of all such legislation for 2024 is not immediately feasible.
