The OECD on 15 January 2025 released additional Pillar Two Administrative Guidance on the GloBE Model Rules and several related documents aimed at streamlining the administration of the global minimum tax. This includes guidance on transition rules on deferred tax assets (Article 9.1 Model Rules), a list of countries that have (temporary) ‘qualified’ Pillar Two rules, an updated GIR and related Commentary, an updated XML Schema, and a Multilateral Competent Authority Agreement (MCAA) to facilitate central filing and exchange of the GIR.

In the beginning of December 2024, a draft bill with some amendments to the Pillar Two legislation has been submitted to Parliament, currently pending the required legislative process and voting. The proposed changes are mainly to reflect aspects of the OECD’s Administrative Guidance.

On December 18, 2024, the Global Minimum Tax of MNE Groups and Large-Scale Domestic Groups Law was published in the Cyprus Government Gazette (completing in this way the legislative process), transposing into Cyprus national law the relevant EU Directive issued on December 14, 2022, on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups.

The Law provides that the main rule named as the Qualified Income Inclusion Rule is practically effective as from 2024, the secondary rule named as the Qualified Undertaxed Profits Rule is practically effective as from 2025, and the Cyprus domestic minimum top-up tax also practically effective as from 2025.

The adoption of the Law does not modify Cyprus’ corporate income tax legislation; rather the Law introduces an additional tax legislation which is only to be applied in parallel to the corporate income tax legislation for the groups within scope.

On 5 December 2024, the Federal Ministry of Finance published a second draft of the German Pillar 2 Tax Amendment Act.

On 23 December 2024, draft law n°8396 was enacted, amending certain provisions of the Pillar Two Law. The amendments broadly incorporate the Administrative Guidance issued by the OECD until June 2024 and clarify some important principles which could be relevant for Luxembourg businesses impacted by the rules.

On 15 November 2024, the Polish Act implementing the provisions of the EU global minimum tax Directive into the Polish legal system was signed by the President. The law will introduce IIR, UTPR, and QDMTT. The law generally came into effect from January 1, 2025. Transitional provisions provide for the optional possibility of retroactive application of the provisions of the law from January 1, 2024 (with some exceptions - UTPR rules).

The proposed regime, presented under Draft Law no. 21/XVI/1.ª, was approved by the Portuguese Parliament on 18 October 2024 and was published in the Portuguese Official Gazette on 9 November 2024.

On 21 December 2024, Law 7/2024 of 20 December was published in the Official State Gazette (BOE), which, among others, transposes Council Directive (EU) 2022/2523 in Spain introducing a complementary tax to guarantee a minimum global level of taxation for multinational groups and large national groups