On 29 September 2023, the Japanese National Tax Agency (NTA) issued guidance on the income inclusion rule (IIR) under the OECD pillar two model which was introduced as part of the 2023 tax measures. The guidance explains how companies can use the de minimis exclusion and the transitional country-by-country (CbC) report safe harbor to reduce their compliance burden under the Pillar Two global minimum tax. The guidance emphasizes that when interpreting the Japanese global minimum tax laws and regulations, they should align with and not deviate from the Model Rules and associated documents.