The OECD has released an updated edition of the Central Record of Legislation with Transitional Qualified Status for the Pillar 2 global minimum tax as of 31 March 2025.

The global minimum tax follows a rule order that limits applying minimum tax rules in one jurisdiction if “qualified” rules exist in another. In 2024, the Inclusive Framework on BEPS introduced a fast-track process to confirm a jurisdiction’s qualified status for domestic legislation on a transitional basis.

The Central Record, first published in January 2025, lists jurisdictions with minimum tax laws that have gained transitional qualified status and their effective dates. The latest update adds Guernsey and Spain to the list of jurisdictions with Qualified Income Inclusion Rules, Qualified Domestic Minimum Top-up Tax Rules, and QDMTT Safe Harbours. It will be regularly updated to include new minimum tax laws from the fast-track process.

Background

1. 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.

2. The GloBE Model Rules were approved and released by the Inclusive Framework on 20 December 2021 Tax Challenges Arising from Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two): Inclusive Framework on BEPS (OECD, 2021. 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 (the “UN Model Double Tax Convention”) (UN, 2021[2]) and the Model Tax Convention on Income and on Capital: Condensed Version 2017, (the “OECD Model Tax Convention”) (OECD, 2017[3]).

3. The Commentary to the GloBE Model Rules was first approved and released by the Inclusive Framework on 14 March 2022 Tax Challenges Arising from the Digitalisation of the Economy – Commentary to the Global Anti-Base Erosion Model Rules (Pillar Two), First Edition: Inclusive Framework on BEPS (OECD, 2022[4]).

The Commentary clarifies the interpretation and operation of the provisions in the GloBE Model Rules and includes some examples illustrating how the rules apply to specific fact patterns. The Commentary is intended to promote a consistent and common interpretation of the GloBE Model Rules in order to provide certainty for MNE Groups and to facilitate coordinated outcomes among implementing jurisdictions. Although the Commentary is detailed and comprehensive, it does not provide guidance on every aspect of the GloBE Model Rules.

4. The GloBE Model Rules envision that the Inclusive Framework may issue guidance on both the interpretation and the operation of the rules. The Inclusive Framework has provided interpretive guidance to ensure consistent and common interpretation of the GloBE Rules, provide certainty for MNE Groups and facilitate coordinated and transparent outcomes under the rules. Once agreed, the Administrative Guidance is incorporated into the Commentary as it supplements or replaces paragraphs in the Commentary or explains how to apply the language of the rules to particular fact patterns.

Administrative Guidance – Central Record

5. The Inclusive Framework released a first version of the Central Record on 15 January 2025 with legislation that had completed the transitional qualification mechanism process for the IIR, DMTT or QDMTT Safe Harbour. This document includes an updated version of the Central Record as of 28 March 2025 to reflect that additional legislation has completed the transitional qualification mechanism process. This Administrative Guidance will be incorporated into the Commentary.

The currently listed jurisdictions and the effective date of the legislation are as follows:

Qualified Income Inclusion Rules (29 jurisdictions): Australia (1 January 2024), Austria (31 December 2023), Belgium (31 December 2023), Bulgaria (31 December 2023), Canada (31 December 2023), Croatia (31 December 2023), Czech Republic (31 December 2023), Denmark (31 December 2023), Finland (31 December 2023), France (31 December 2023), Germany (31 December 2023), Greece (31 December 2023), Guernsey (1 January 2025), Hungary (31 December 2023), Ireland (31 December 2023), Italy (31 December 2023), Japan (1 April 2024), Korea (South) (1 January 2024), Liechtenstein (1 January 2024), Luxembourg (31 December 2023), Netherlands (31 December 2023), Norway (1 January 2024), Romania (31 December 2023), Slovenia (31 December 2023), Spain (31 December 2023), Sweden (31 December 2023), Turkey (1 January 2024), United Kingdom (31 December 2023), and Vietnam (1 January 2024).

Qualified Domestic Minimum Top-up Tax Rules and QDMTT Safe Harbours (30 jurisdictions): Australia (1 January 2024), Austria (31 December 2023), Barbados (1 January 2024), Belgium (31 December 2023), Bulgaria (31 December 2023), Canada (31 December 2023), Croatia (31 December 2023), Czech Republic (31 December 2023), Denmark (31 December 2023), Finland (31 December 2023), France (31 December 2023), Germany (31 December 2023), Greece (31 December 2023), Guernsey (1 January 2025), Hungary (31 December 2023), Ireland (31 December 2023), Italy (31 December 2023), Liechtenstein (1 January 2024), Luxembourg (31 December 2023), Netherlands (31 December 2023), Norway (1 January 2024), Romania (31 December 2023), Slovak Republic (31 December 2023), Slovenia (31 December 2023), Spain (31 December 2023), Sweden (31 December 2023), Switzerland (1 January 2024), Turkey (1 January 2024), United Kingdom (31 December 2023), and Vietnam (1 January 2024).