Last updated: This central record is current as at 31 March 2025.
Central Record of Legislation with Transitional Qualified Status
This page provides the central record of legislation with transitional qualified status as finalised under the transitional qualification mechanism.
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This page details the central record of legislation with qualified status for a transitional period, as determined under the transitional qualification mechanism. This central record will be updated on a regular basis and in a timely manner, after a self-certification that has been submitted to the OECD/G20 Inclusive Framework on BEPS has completed the agreed transitional qualification mechanism process. The fact that a jurisdiction’s legislation is not included in this central record does not mean that the legislation is not qualified; rather it means that, as at the date of publication, the process provided for under the transitional qualification mechanism has not yet been initiated or completed for that legislation.
The relevant legislation set out in the tables below will be treated as qualified from the effective date of the legislation, which is the date when that legislation becomes applicable to in-scope taxpayers (i.e. the date on or after which the first covered Fiscal Year of an in-scope MNE Group starts). While recognition of qualified status is important for determining the order in which global minimum tax rules apply, there is no requirement for a jurisdiction to introduce such rules. Jurisdictions may have alternative ways of ensuring that MNE Groups pay an effective rate of tax at least 15% on the income arising in their jurisdiction and achieving policy outcomes consistent with the global minimum tax.
Qualified Income Inclusion Rules
Source information: This table is based on information extracted from Annex B of the Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2023), as published and updated through any new versions of the Central Record that were subsequently agreed by the OECD/G20 Inclusive Framework on BEPS. This interactive version is designed to facilitate access to key details on Qualified Income Inclusion Rules as at 31 March 2025.
Qualified Domestic Minimum Top-up Tax Rules and QDMTT Safe Harbours
The central record below indicates if a DMTT is a Conditional DMTT for 2024. A Conditional DMTT is one that only applies to a Constituent Entity when the MNE Group is subject to the GloBE Rules in another jurisdiction. The Inclusive Framework has agreed that a DMTT that is a Conditional DMTT for 2024 can be recognised as qualified under certain circumstances, including that the DMTT will not be conditional in any other year.
Where a jurisdiction has introduced a DMTT that also applies below the EUR 750 million threshold, then the qualified status is only applicable to legislation to the extent that legislation applies to an MNE Group which meets the EUR 750 million threshold.
Source information: This table is based on information extracted from Annex B of the Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2023), as published and updated through any new versions of the Central Record that were subsequently agreed by the OECD/G20 Inclusive Framework on BEPS. This interactive version is designed to facilitate access to key details on Qualified Domestic Minimum Top-up Taxes and QDMTT Safe Harbours as at 31 March 2025.
