The global minimum tax is implemented by jurisdictions through the introduction of a qualified income inclusion rule (IIR), a qualified UTPR, and a qualified domestic minimum top-up tax (QDMTT). On January 15th, 2025, a central record of legislation with transitional qualified status was published on the OECD’s website. The central record sets out 27 jurisdictions with a qualified IIR and 28 jurisdictions with a QDMTT that are also eligible for the QDMMT safe harbour. A few days later, the Austrian Ministry of Finance published an information which adopts the list published on the OECD’s website. Michael Schilcher and Albert Steiner explain the international background of the central record of legislation with transitional qualified status and the underlying qualification mechanism in more detail and provide an outlook on the expected more comprehensive full legislative review as well as the ongoing monitoring of implementing jurisdictions.
