Pillar 2 / GLOBE Rules (Global Minimum Tax)

OECD/G20 Inclusive Framework rules establishing a 15% global minimum effective corporate-tax rate for multinational enterprises with consolidated annual revenue above EUR 750 million. Implemented through three coordinated mechanisms: the Income Inclusion Rule (IIR — parent-jurisdiction top-up tax), the Undertaxed Profits Rule (UTPR — backstop top-up tax), and the Qualified Domestic Minimum Top-up Tax (QDMTT — host-jurisdiction option to capture the top-up locally). EU member states implemented from January 2024 via the Pillar 2 Directive. Major participating jurisdictions: EU, UK, Australia, Canada, Japan, Korea, Switzerland, Singapore, Hong Kong, UAE (with QDMTT). Direct effect on individual relocators is limited; indirect effect on cross-border employer / company structuring is significant.