The OECD issued an update on 31 March 2025, in which Guernsey has been added as a jurisdiction with a qualified income inclusion rule (IIR), domestic minimum top-up tax rule (QDMTT), and meeting QDMTT safe harbor standards. This should prevent another jurisdiction from imposing a top-up tax on low-tax profits if those profits have already been taxed under Guernsey’s “qualified” rules, which align with global minimum tax rules.

The OECD/G20 Inclusive Framework on BEPS records jurisdictions with transitional qualified status, listing those whose local implementation of the Pillar Two global minimum tax rules is deemed “qualified”. The lists cover jurisdictions’ implementation of the domestic minimum top-up tax rule (QDMTT) and income inclusion rule (IIR) and assess whether a jurisdiction’s QDMTT meets the criteria for the safe harbor to apply.

The Pillar Two global minimum tax rules include an agreed order, preventing a jurisdiction from taxing low-tax profits if those profits have already been taxed under “qualified” rules elsewhere.

In October 2021 members of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (Inclusive Framework) agreed a two-pillar solution to reform the international tax framework in response to the challenges of digitalisation of the economy.  As part of the October Statement, Inclusive Framework members agreed to a coordinated system of Global anti-Base Erosion (GloBE) rules that are designed to ensure large multinational enterprises pay a minimum level of tax on the income arising in each jurisdiction where they operate. In the October Statement, it was agreed that the GloBE Rules would have the status of a common approach. Under this common approach, jurisdictions are not required to adopt the GloBE rules, but, if they choose to do so, they will implement and administer the rules in a way that is consistent with the agreed outcomes. The common approach also means that Inclusive Framework members accept the application of the GloBE rules applied by other members, including agreement as to rule order and the application of any agreed safe harbours.

The OECD’s lists of qualified rules are based on a simplified transitional qualification mechanism using self-certification by implementing jurisdictions.