Browse all rules ↓

Qualified status and Inclusive Framework peer review

Applies
FY2024 onwards
Reviewed
Rule
P2-QSTAT-2026.1
By

How is a jurisdiction's Pillar Two law treated as qualified?

Through the Inclusive Framework's transitional qualification mechanism, recorded in the Central Record. Absence from it does not mean unqualified.

Per Consolidated Commentary to the GloBE Model Rules (May 2026), Annex B, Central Record for purposes of the Global Minimum Tax

The Inclusive Framework has developed a transitional qualification mechanism, a simplified procedure that allows the recognition of the qualified status of implementing jurisdictions' legislation on a temporary basis, pending a full legislative review and ongoing monitoring process. Its results are set out in the Central Record. Legislation listed there is treated as qualified from the effective date of the legislation, which is the date on or after which the first covered Fiscal Year of an in-scope MNE Group starts. The fact that a jurisdiction's legislation is not included does not mean that the legislation is not qualified; it means that the process had not been initiated or completed for it at the date of publication.

Qualified status fixes the order in which the taxes apply across jurisdictions. A taxpayer needs it for jurisdictions other than its own, and cannot determine it for itself.

A record to read, not a test to apply

Why it matters

  • A Qualified Domestic Minimum Top-up Tax is credited before any other charge
  • A Qualified IIR higher in the chain switches off the IIR below it
  • The UTPR reaches only what no Qualified IIR has

How status is recognised

A jurisdiction self-certifies; the transitional qualification mechanism recognises the status on a temporary basis; a full legislative review and ongoing monitoring — peer review — follow. The Central Record is updated as jurisdictions complete the process.

Listed

Treated as qualified from the effective date shown. A Fiscal Year starting on or after that date is within it.

Not listed

No conclusion follows. This page returns no answer in that case, neither qualified nor not.

Two columns for a domestic top-up tax

The record shows qualified status and, separately, whether the tax meets the QDMTT Safe Harbour standards. It also marks a Conditional DMTT for 2024.

Dated

The archived record is current as at 1 December 2025. Take the entry from the current record.

Order of testing

  1. 1

    Inputs requiring your determination

    Every input the computation reaches must be supplied; nil is entered, not left blank.

  2. 2

    The Central Record

    Listed or not; unlisted legislation gets no answer.

  3. 3

    The effective date on the Central Record

    The Fiscal Year must start on or after it.

Examples

Illustrative scenarios — ours, not the authority’s — each computed live by this rule. Change any fact and the outcome is the rule’s, not a hand-written answer.

A listed Income Inclusion Rule

Legislation listed with an effective date of 1 January 2024, for a calendar-year 2026 Fiscal Year.

Computed

The legislation is treated as a Qualified IIR for the Fiscal Year as computed: it is listed in the Central Record, which treats listed legislation as qualified from its effective date of 2024-01-01, and the Fiscal Year starts on 2026-01-01, on or after that date. The status is transitional — recognised under the transitional qualification mechanism pending a full legislative review and ongoing monitoring — and the record is updated as jurisdictions complete the process. Based on what you supplied.

Workings

Effective date on the Central RecordAnnex B, paragraph 2 — as supplied
2024-01-01
Start of the Fiscal YearAs supplied — on or after the effective date
2026-01-01

Decided by the effective date on the central record

A Fiscal Year that starts too early

A domestic top-up tax effective 1 January 2025, for a Fiscal Year that started on 1 July 2024.

Computed

The legislation is not treated as a Qualified Domestic Minimum Top-up Tax for the Fiscal Year as computed: the Central Record treats listed legislation as qualified from its effective date of 2025-01-01, the date on or after which the first covered Fiscal Year starts, and this Fiscal Year starts on 2024-07-01, before it. Based on what you supplied.

Workings

Effective date on the Central RecordAnnex B, paragraph 2 — as supplied
2025-01-01
Start of the Fiscal YearAs supplied — before the effective date
2024-07-01

Decided by the effective date on the central record

Legislation not yet on the record

A newly enacted Income Inclusion Rule that has not completed the process.

Computed

No status is reported: the legislation is not listed in the Central Record as a Qualified IIR. The record states that this does not mean the legislation is not qualified — only that the transitional qualification mechanism had not been initiated or completed for it at the date of publication. Qualified status is determined through the Inclusive Framework and is not decided here; whether to treat the rule as qualified in the meantime requires your determination, and the implementing jurisdiction's own law may say. Based on what you supplied.

Decided by the central record

Try it

Supply the facts and this rule computes the outcome in your browser, live. Leave a determination undecided and it blocks the result — it is never read as a no.

Not computed yet

2 inputs still need your determination:

  • Is the legislation an Income Inclusion Rule, a domestic minimum top-up tax, or a side-by-side regime?
  • Is the legislation listed in the current Central Record for purposes of the Global Minimum Tax, in the table for that kind of rule?

Computed in your browser from the figures you supply. Nothing is sent anywhere, and the result is a computation against a rule — reference, not tax advice.

Sources

Share this rule

Reference, not tax advice.

Pankaj Agarwal — Tax Technology Leader