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.

UTPR on CompPress | Transfer Pricing Resources

Germany Issues Draft Regulation Listing Jurisdictions With Qualifying Pillar Two Status