Germany Issues Draft Regulation Listing Jurisdictions With Qualifying Pillar Two Status

Wed, 08 Apr 2026 00:00:00 +0000

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.

Switzerland Issues Communications Implementing OECD January 2025 and 2026 Administrative Guidance

Tue, 07 Apr 2026 00:00:00 +0000

The Swiss Federal Tax Administration issued Communications 030-E-2026-f and 031-E-2026-f on April 7, 2026, applying the OECD’s January 2025 and January 2026 Administrative Guidance on the Pillar Two GloBE rules to the Swiss domestic implementation. The Communications adopt the Inclusive Framework’s interpretations of the GloBE rules into Swiss administrative practice for the purposes of the Swiss Qualified Domestic Minimum Top-up Tax and the operation of the IIR and UTPR.

The January 2026 Administrative Guidance includes the Side-by-Side package agreed by the Inclusive Framework on January 5, 2026, which addresses the application of the GloBE rules to US-headquartered MNE groups and recognizes the US tax system as a Qualified Side-by-Side Regime in defined circumstances. Switzerland’s adoption of this guidance brings the Swiss Pillar Two regime into alignment with the latest international consensus and provides administrative certainty for MNE groups with Swiss operations.

QDMTT on CompPress | Transfer Pricing Resources

Germany Issues Draft Regulation Listing Jurisdictions With Qualifying Pillar Two Status

Switzerland Issues Communications Implementing OECD January 2025 and 2026 Administrative Guidance