OECD Pillar Two Implementation Tracker

Of the 46 jurisdictions Tax Atlas tracks, 27 have Pillar Two rules in force, 0 have some rules only, 2 have legislated or announced rules that are not yet effective, 2 are using a deferral, and 15 have no implementation. Status was verified against PwC, KPMG, EY and government sources.

In the Tax Atlas dataset, Bahrain, Bermuda, British Virgin Islands, Cayman Islands, Guernsey, Isle of Man, Jersey keep a 0% headline corporate rate but have a domestic minimum top-up tax (QDMTT). For groups above the €750M threshold, profits there are topped up to a 15% effective rate. Companies below the threshold still pay the headline rate.

No. Pillar Two only applies to multinational groups with consolidated annual revenue of at least €750 million in two of the four preceding years. Individuals, freelancers and smaller companies are out of scope, so the headline personal and corporate rates on the country pages still apply to them.

Partly. On 5 January 2026 the OECD released a Side-by-Side safe harbour that lets groups whose ultimate parent is in a jurisdiction with a qualified side-by-side regime (the United States) elect zero top-up tax under the IIR and UTPR, for fiscal years starting on or after 1 January 2026. A QDMTT still applies to their subsidiaries in jurisdictions that have one.

A QDMTT lets a country top up its own resident entities to 15%, so it keeps the revenue. The IIR lets the parent company's country tax foreign subsidiaries taxed below 15%. The UTPR is a backstop that lets other countries deny deductions when neither of the first two rules has collected the top-up.