On April 8, 2026, Germany issued a Draft Regulation including a list of jurisdictions that hold qualifying status for the purposes of the Income Inclusion Rule (IIR), the Undertaxed Profits Rule (UTPR), the Qualified Domestic Minimum Top-up Tax (QDMTT) and the QDMTT Safe Harbour under the German implementation of the OECD Pillar Two GloBE rules.
The list serves a practical administrative function: under the GloBE framework, the operation of the IIR, UTPR and QDMTT depends on whether the relevant jurisdiction’s domestic regime has been recognized as qualifying. Germany’s Draft Regulation provides authoritative guidance to German-headquartered MNE groups and to German subsidiaries of foreign MNE groups on which jurisdictions can be relied upon for QDMTT Safe Harbour purposes and which jurisdictions’ IIR and UTPR will be respected.
The release follows similar lists published or in draft form by other European jurisdictions and is part of the broader administrative buildout of Pillar Two. For German MNE groups, the most immediate practical implication is the ability to rely on the QDMTT Safe Harbour for jurisdictions appearing on the list, which simplifies the GloBE computation by deferring to the local QDMTT amount. The Draft Regulation is open for comment ahead of finalization.