EU Member States unanimously adopt Directive implementing Pillar Two Global Minimum Tax rules

On 15 December 2022, European Union (EU) Member States unanimously adopted the Minimum Tax Directive via written procedure.

Member States have until 31 December 2023 to transpose the Directive into national legislation.

The Income Inclusion Rule (IIR) will be applicable in EU Member States for fiscal years starting on or after 31 December 2023. The Directive provides for the Undertaxed Profit Rule (UTPR) to apply for fiscal years starting on or after 31 December 2024.