Twenty-two of the 27 Member States of the European Union have carried out the QDMTT, the IIR, and the UTPR in 2025, whereas 5 haven’t.

5 EU Member States can choose for a six-year deferral of Pillar Two implementation, and all of them have carried out so, with Estonia, Latvia, Lithuania, and Malta deferring all guidelines till 2029, whereas Slovakia selectively carried out solely a home top-up tax in 2024.

4 EU Member States—Cyprus, Poland, Portugal, and Spain—have carried out Pillar Two guidelines with delay, regardless of obligations below the EU Directive. In these nations, the principles apply retroactively for 2024.

Amongst eight main European nations outdoors of the European Union, solely Norway, Turkey, and the United Kingdom have carried out a QDMTT, an IIR, and a UTPR by 2025. Switzerland carried out a QDMTT in 2024 and an IIR in 2025, however has not set ahead any plans to implement a UTPR. Iceland is present process public session to implement a QDMTT and an IIR in 2026, with no statements concerning a UTPR. Georgia, Moldova, and Ukraine, the most recent candidates for EU accession, haven’t publicly introduced intentions to implement any Pillar Two guidelines.

In distinction to many European nations, the US has chosen to not implement modifications consistent with the worldwide tax deal. In June 2025, the G7 introduced a political settlement on a worldwide minimal tax “side-by-side” resolution that may exclude US-parented teams from Pillar Two’s IIR and UTPR.

Latest modifications to US worldwide tax guidelines within the One Massive Lovely Invoice Act—web CFC-tested revenue, or NCTI (previously GILTI)—produce an final result much like Pillar Two, regardless of the principles themselves being distinct. NCTI acts at the least tax of between 12.6 p.c and 14 p.c on all overseas revenue of US corporations, utilizing a blended components as a substitute of country-by-country. On account of much less beneficiant overseas tax crediting, the elimination of the substance exclusion, lack of loss carryovers, and curiosity deductibility guidelines, the US system could also be extra stringent than Pillar Two.

Since extraterritorial taxation measures just like the IIR and UTPR can danger tax and commerce disputes, European nations that negotiate free commerce agreements on their very own, fairly than as half of a bigger buying and selling bloc, face stronger incentives to keep away from measures that might provoke retaliation.