China's tax authority has released implementation guides for global minimum tax rules in three key jurisdictions to assist Chinese multinational enterprises with overseas compliance, even as Beijing has not adopted the 15% minimum tax framework domestically.
China’s State Taxation Administration (STA) has published comprehensive guidance to help Chinese companies navigate global minimum tax (GMT) rules in Denmark, Ireland, and the United Arab Emirates (UAE) despite not adopting these rules domestically.
Supporting outbound investment compliance
The Guidance on Country-by-Country Implementation of the Global Minimum Tax Rules was unveiled at a conference in Chongqing on 29 April 2026. The guidance provides Chinese enterprises with detailed information on GMT implementation in the three countries, including background, key provisions, and administrative requirements.
The guidance incorporates direct links to original legislation from each jurisdiction and relevant OECD Pillar Two documents, including model rules, commentary, and the side-by-side comparison system.
Key tax framework details
The guidelines explain how the OECD’s Pillar Two framework establishes a 15% minimum tax rate for multinational groups with annual revenues exceeding EUR 750 million. Companies can reference detailed information on GloBE income calculation, adjusted covered taxes, safe harbour provisions, registration requirements, filing deadlines, and penalties for non-compliance in each country.
Compiled by the State Taxation Administration’s International Taxation Department in collaboration with local tax authorities, the guidance serves as a non-commercial reference tool.
The administration emphasises that while the content draws from publicly available laws and regulations, official interpretations from each jurisdiction take precedence. The State Taxation Administration disclaims liability for any losses arising from the use of this guidance and retains full copyright, requiring proper attribution for any reproduction.
Below are the summaries for the implementation of the Global Minimum Tax rules in Denmark, Ireland, and the UAE:
Denmark
Denmark officially introduced the global minimum tax through the Minimum Tax Act, passed on 7 December 2023.
The legislation incorporates the Income Inclusion Rule (IIR), the Undertaxed Profits Rule (UTPR), and a Domestic Minimum Top-up Tax (DMTT). The IIR and DMTT apply to fiscal years starting on or after 31 December 2023. The UTPR generally applies to fiscal years starting on or after 31 December 2024.
It applies to multinational enterprise (MNE) groups with annual consolidated revenues of at least EUR 750 million in at least two of the four preceding fiscal years.
According to OECD records, Denmark’s legislation has achieved transitional qualified status for its IIR and DMTT, including meeting the QDMTT Safe Harbour requirements.
Ireland
Ireland transposed the EU Global Minimum Tax Directive into domestic law via the Finance (No.2) Act 2023, which inserted Part 4A into the Taxes Consolidation Act 1997. This was further updated by the Finance Act 2024 to align with the latest OECD guidance.
The framework includes the IIR, UTPR, and DMTT. Both the IIR and DMTT are effective for fiscal years starting on or after 31 December 2023. The UTPR applies to fiscal years starting on or after 31 December 2024, with some specific early-applicability exceptions for certain EU-linked entities.
The rules apply to MNEs or large-scale domestic groups with annual revenues of EUR 750 million or more in at least two of the previous four years. Ireland’s IIR and DMTT are recognised as transitional qualified, and its DMTT qualifies for the QDMTT Safe Harbour.
United Arab Emirates (UAE)
The UAE’s foundation for the global minimum tax is Cabinet Decision No. 142 of 2024, supplemented by Ministerial Decision No. 88 of 2025, which adopts OECD Model Rules and guidance.
The UAE has primarily focused on implementing a Qualified Domestic Minimum Top-up Tax (QDMTT) to ensure low-taxed profits within its jurisdiction are taxed locally first. The UAE’s DMTT rules apply to fiscal years starting on or after 1 January 2025.
Similar to the other jurisdictions, it targets MNE groups with annual consolidated revenues reaching the EUR 750 million threshold in at least two of the four preceding years.
The UAE’s legislation is currently recognised by the OECD as a transitional QDMTT that meets QDMTT Safe Harbour standards.
