Global Daily Tax News, OECD Adds To List Of Pillar Two Legislation With Qualified Status, (Aug 25, 2025)

On August 18, 2025, the OECD updated its Central Record of Legislation with Transitional Qualified Status under Pillar Two of its two-pillar international tax reform framework.

Pillar Two provides for a minimum 15-percent corporate tax rate on the profits of large multinational groups on a jurisdiction-by-jurisdiction basis.

Countries' Pillar Two frameworks are being reviewed by the OECD to support the administration of the framework internationally, to ensure that top-up tax taxing rights are properly attributed to the appropriate territories under the Pillar Two rule order, providing first for the application of a Qualified Minimum Top-up Tax, followed by application of the Qualified Income Inclusion Rule, and then the Undertaxed Profits Rule.

The latest update notes that, with effect from January 1, 2025, the following territories are deemed to have Qualified Income Inclusion Rules:

• Gibraltar;

• Guernsey;

• Indonesia;

• the Isle of Man;

• Jersey;

• Malaysia;

• New Zealand;

• Singapore;

• Switzerland; and

• Thailand.

Further, the Central Record lists the following territories as having Qualified Domestic Minimum Top-up Tax legislation that is effective from January 1, 2025:

• Brazil;

• Guernsey;

• Indonesia;

• The Isle of Man;

• Malaysia;

• Singapore;

• Thailand; and

• The United Arab Emirates.

The Central Record also lists territories that have been accorded qualified status for legislation that entered into force prior to January 1, 2025, and lists for each territory the relevant law providing for the implementation of either an Income Inclusion Rule or a Qualified Domestic Top-up Tax or both.