Tax intelligence tracker

Pillar Two implementation

Compare source-reviewed implementation status across the GCC and selected Asian investment hubs, while keeping unverified rule-level positions visibly pending.

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Source-backed staging data. A domestic top-up tax, IIR and UTPR are separate rules. A pending row is not evidence that a rule is absent. Source review date: 2026-09-03.

Region8 of 8 records

Pillar Two implementation tracker
Jurisdiction	Headline treatment	Verification	What it means	Timing	Source
Qatar	In force	Source reviewed	Domestic Minimum Top-Up Tax (DMTT) and Income Inclusion Rule (IIR). Applies to in-scope multinational groups, not every business.	Fiscal years commencing on or after 1 January 2025.	Qatar GTA · Global Minimum Tax
United Arab Emirates	In force	Source reviewed	Domestic Minimum Top-up Tax (DMTT) for in-scope multinational groups. This does not mean that all Pillar Two rules are implemented.	Financial years starting on or after 1 January 2025.	UAE Ministry of Finance · Top-up Tax
Saudi Arabia	Not verified	Verification pending	No current primary-source implementation conclusion is published here yet. This is not a statement that no rules exist.	Timing not yet source-verified.	Source verification pending
Bahrain	DMTT in force	Source reviewed	Domestic Minimum Top-Up Tax applies to constituent entities of in-scope multinational groups. This is not a general corporate income tax.	Financial years starting on or after 1 January 2025.	Bahrain NBR · DMTT Executive Regulations
Kuwait	DMTT in force	Source reviewed	Domestic Minimum Top-Up Tax applies to in-scope multinational groups; the source states that Kuwait did not introduce an IIR or UTPR with this law.	Tax periods starting on or after 1 January 2025.	EY · Kuwait DMTT implementation
Oman	IIR + DMTT in force	Source reviewed	Oman’s supplementary tax law implements an Income Inclusion Rule and Domestic Minimum Top-Up Tax for in-scope multinational groups.	Financial years starting on or after 1 January 2025.	Oman Royal Decree 70/2024
Singapore	IIR + DTT in force	Source reviewed	Singapore applies the Income Inclusion Rule and a domestic top-up tax to in-scope multinational groups.	Financial years starting on or after 1 January 2025.	IRAS · GloBE rules and DTT
Malaysia	MTT + DTT in force	Source reviewed	Malaysia applies Multinational Top-up Tax and Domestic Top-up Tax to in-scope multinational groups.	Financial years starting on or after 1 January 2025.	HASiL · Global Minimum Tax

Historical change record

Pillar Two implementation history

A selective, source-reviewed record of material historical changes behind the current tracker position. Values labelled “at this date” are historical states, not today’s rate or status.

Jurisdiction

Historical timeline — not current rates.The current tracker position is shown on every card and in the table above.

7verified changesEvery entry links to the public source used for the history record.

Rule effectiveFiscal years commencing on or after 1 January 2025Qatar

Current tracker positionIn force

Before this changeQatar Pillar Two framework not yet effective

Changed at this date toDMTT + IIR effective for in-scope MNE groups

Qatar's Global and Domestic Minimum Tax framework applies a Domestic Minimum Top-Up Tax and Income Inclusion Rule to in-scope multinational groups.

Why it matters

For large groups, the jurisdiction-level tax outcome can no longer be assessed only through Qatar's ordinary corporate-tax and incentive rules.

Source reviewed · Primary public sourceQatar GTA · Global Minimum Tax

Rule effectiveFinancial years starting on or after 1 January 2025United Arab Emirates

Current tracker positionIn force

Before this changeUAE DMTT not yet effective

Changed at this date toDomestic Minimum Top-Up Tax effective for in-scope MNE groups

The UAE Domestic Minimum Top-Up Tax became effective for financial years starting on or after 1 January 2025.

Why it matters

The DMTT adds a minimum-tax overlay for large multinational groups even where ordinary UAE corporate-tax or free-zone outcomes are lower.

Source reviewed · Primary public sourceUAE Ministry of Finance · Top-up Tax

Rule effectiveFinancial years starting on or after 1 January 2025Bahrain

Current tracker positionDMTT in force

Before this changeBahrain DMTT not yet effective

Changed at this date toDomestic Minimum Top-Up Tax effective for in-scope MNE groups

Bahrain's DMTT became effective for financial years starting on or after 1 January 2025.

Why it matters

The DMTT creates a 15% minimum-tax mechanism for in-scope groups despite Bahrain's broader no-general-CIT environment outside specified sectors.

Source reviewed · Primary public sourceBahrain NBR · DMTT FAQs

Rule effectiveTax periods starting on or after 1 January 2025Kuwait

Current tracker positionDMTT in force

Before this changeKuwait DMTT not yet effective

Changed at this date toDomestic top-up tax effective for in-scope MNE groups

Kuwait implemented a domestic top-up tax for multinational groups within scope from tax periods starting on or after 1 January 2025.

Why it matters

The measure creates a separate minimum-tax layer for large multinational groups and should not be confused with Kuwait's ordinary foreign-corporate income-tax regime.

Source reviewed · Public professional sourceEY · Kuwait DMTT implementation

Rule effective1 January 2025Oman

Current tracker positionIIR + DMTT in force

Before this changeOman top-up-tax law not yet effective

Changed at this date toIIR + DMTT framework in force for in-scope MNE groups

Royal Decree 70/2024 brought Oman's top-up-tax law into force from 1 January 2025.

Why it matters

The regime introduces a Pillar Two overlay for large multinational groups in addition to Oman's ordinary corporate-tax and zone-incentive framework.

Source reviewed · Public legal textOman · Royal Decree 70/2024

Rule effectiveFinancial years starting on or after 1 January 2025Singapore

Current tracker positionIIR + DTT in force

Before this changeMTT and DTT not yet effective

Changed at this date toIncome Inclusion Rule + domestic top-up tax in force

Singapore applies its Multinational Enterprise Top-up Tax and Domestic Top-up Tax for financial years starting on or after 1 January 2025.

Why it matters

The rules add a 15% minimum-tax framework for in-scope groups and change how Singapore incentives are assessed for large multinationals.

Source reviewed · Primary public sourceIRAS · GloBE rules and DTT

Rule effectiveFinancial years starting on or after 1 January 2025Malaysia

Current tracker positionMTT + DTT in force

Before this changeMTT and DTT not yet effective

Changed at this date toMultinational Top-up Tax + Domestic Top-up Tax in force

Malaysia's Multinational Top-up Tax and Domestic Top-up Tax apply for financial years starting on or after 1 January 2025.

Why it matters

The regime changes the value and modelling of low effective tax outcomes for large multinational groups operating in Malaysia.

Source reviewed · Primary public sourceHASiL · Global Minimum Tax

Tracker methodology

Scope
The headline field reflects the verified implementation position in the shared Tax & Markets benchmark, not a full GloBE applicability analysis.

Status control
Where the source set does not support a conclusion, the row remains marked verification pending rather than inferring implementation.

Change history
The history records verified effective milestones only. Historical states are shown separately from the current tracker position, and a DMTT, IIR and UTPR remain separate rules. History reviewed 10 September 2026.

Full methodology →

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Jurisdiction

Headline treatment

Verification

What it means

Timing

Source

Qatar

In force

Source reviewed

Domestic Minimum Top-Up Tax (DMTT) and Income Inclusion Rule (IIR). Applies to in-scope multinational groups, not every business.

Fiscal years commencing on or after 1 January 2025.

Qatar GTA · Global Minimum Tax

United Arab Emirates

In force

Source reviewed

Domestic Minimum Top-up Tax (DMTT) for in-scope multinational groups. This does not mean that all Pillar Two rules are implemented.

Financial years starting on or after 1 January 2025.

UAE Ministry of Finance · Top-up Tax

Saudi Arabia

Not verified

Verification pending

No current primary-source implementation conclusion is published here yet. This is not a statement that no rules exist.

Timing not yet source-verified.

Source verification pending

Bahrain

DMTT in force

Source reviewed

Domestic Minimum Top-Up Tax applies to constituent entities of in-scope multinational groups. This is not a general corporate income tax.

Financial years starting on or after 1 January 2025.

Bahrain NBR · DMTT Executive Regulations

Kuwait

DMTT in force

Source reviewed

Domestic Minimum Top-Up Tax applies to in-scope multinational groups; the source states that Kuwait did not introduce an IIR or UTPR with this law.

Tax periods starting on or after 1 January 2025.

EY · Kuwait DMTT implementation

Oman

IIR + DMTT in force

Source reviewed

Oman’s supplementary tax law implements an Income Inclusion Rule and Domestic Minimum Top-Up Tax for in-scope multinational groups.

Financial years starting on or after 1 January 2025.

Oman Royal Decree 70/2024

Singapore

IIR + DTT in force

Source reviewed

Singapore applies the Income Inclusion Rule and a domestic top-up tax to in-scope multinational groups.

Financial years starting on or after 1 January 2025.

IRAS · GloBE rules and DTT

Malaysia

MTT + DTT in force

Source reviewed

Malaysia applies Multinational Top-up Tax and Domestic Top-up Tax to in-scope multinational groups.

Financial years starting on or after 1 January 2025.

HASiL · Global Minimum Tax

Tracker methodology

Scope
The headline field reflects the verified implementation position in the shared Tax & Markets benchmark, not a full GloBE applicability analysis.

Status control
Where the source set does not support a conclusion, the row remains marked verification pending rather than inferring implementation.

Full methodology →