Update on Global Minimum Tax (Pillar 2) developments

14 September 2022 - On Friday, 9 September 2022 the governments of Germany, France, Italy, Spain and the Netherlands issued a joint statement confirming the intention to implement a Global Minimum Tax (Pillar 2). In essence, the statement mentions that even though the European Union (EU)-wide implementation of Pillar 2 is preferred (by means of an unanimously adopted EU Pillar 2 Directive), the countries will move forward with the implementation even in the absence of an EU-wide agreement if such is not obtained over the coming weeks. 

This announcement is just the latest development around Pillar 2 that took place recently. Other jurisdictions have published their implementation projects during the summer break, which are summarized in the table below.

As the whole process is still constantly moving, it is difficult to predict the final outcome. However, the above summary of developments can be seen as a clear push to implement Pillar 2 in the EU and other parts of the world in 2024.

Jurisdictions have published their implementation projects during the summer break, among others including:


Draft legislation published to introduce the Income Inclusion Rules (IRR) as of 1 January 2024

South Korea

Draft legislation published to introduce both IIR and
Under Taxes Payments Rules (UTPR) from 1 January 2024

Hong Kong

Communique published to delay the introduction of the IIR to 2024


Draft legislation published to introduce a qualified domestic minimum tax, IIR and UTRP into domestic legislation applicable as of 1 January 2024

Silence before the storm?

There is growing consent, that the Global Minimum Tax is not a matter of if, but when, which is further emphasized by the weight of the announcement from Friday. Today, there is still time to act and prepare: the global minimum provides for a major change in global tax landscape with many untested rules and interpretations.

Faced with final legislation, Multinational Enterprise (MNE) Groups will have to act and anticipate impact of these rules to their organization, whereby the additional layer of taxes due could require significant adjustments to reporting processes, reporting systems and a shift of responsibilities within the tax and accounting departments of these organizations. 

Deloitte has developed a number of tools which can help business model the impact as well as understand the data requirements.

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