Global Minimum Tax: Updated list of qualified jurisdictions

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OECD published the updated list of countries, including Italy, that have obtained the transitional status of qualified legislation concerning the Income Inclusion Rule, the Undertaxed Profit or Payment Rule, or the Qualified Domestic Minimum Top-up Tax, following the review process conducted by the OECD Inclusive Framework on BEPS Pillar II.

The Global Minimum Tax of Pillar II

On october 8, 2021, within the OECD/G20 Inclusive Framework (which now includes 147 member States), an agreement was reached among participating countries as part of the reform of the international tax system. This agreement introduced a two Pillar solution to address the tax challenges arising from the digitalization of the economy. Pillar II was specifically designed to ensure that multinational enterprises (MNEs) pay a minimum level of tax on the profits they generate globally. To this end, with the publication of the Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy and the subsequent development of the Global Anti-Base Erosion Model Rules (GloBE), a global minimum tax (GMT) of 15% was established. This minimum tax applies in each country where a multinational operates, provided that the country has joined the OECD BEPS Pillar 2 framework.

The Global Minimum Tax (GMT) aims to establish a minimum level of taxation for domestic and multinational groups (including those with either a parent company or even just a subsidiary located in an EU member state) that have a total consolidate...