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It also describes the peer review’s purpose and how next steps proceed.",{"@graph":14,"@context":73},[15,34,56],{"@type":16,"itemListElement":17},"BreadcrumbList",[18,23,27,31],{"item":19,"name":20,"@type":21,"position":22},"https://docshare.wps.com","Home","ListItem",1,{"item":24,"name":25,"@type":21,"position":26},"https://docshare.wps.com/document/","Document",2,{"item":28,"name":29,"@type":21,"position":30},"https://docshare.wps.com/document/exam/","Exam",3,{"item":32,"name":10,"@type":21,"position":33},"https://docshare.wps.com/document/qualified-status-under-the-global-minimum-tax-questions-and-answers/375165/",4,{"url":32,"name":10,"@type":35,"image":36,"author":41,"headline":10,"publisher":44,"fileFormat":47,"inLanguage":8,"description":12,"dateModified":48,"datePublished":49,"encodingFormat":47,"isAccessibleForFree":50,"interactionStatistic":51},"DigitalDocument",{"url":37,"@type":38,"width":39,"height":40},"https://docshare.wps.com/thumbnails/qualified-status-under-the-global-minimum-tax-questions-and-answers/375165.png","ImageObject",300,407,{"name":42,"@type":43},"8796093062539","Person",{"url":19,"name":45,"@type":46},"DocShare","Organization","application/pdf","2026-11-08","2026-09-24",true,{"@type":52,"interactionType":53,"userInteractionCount":55},"InteractionCounter",{"@type":54},"ViewAction",7,{"@type":57,"mainEntity":58},"FAQPage",[59,65,69],{"name":60,"@type":61,"acceptedAnswer":62},"Are jurisdictions required to adopt the Global Minimum Tax?","Question",{"text":63,"@type":64},"The Global Minimum Tax reflects a common approach among Inclusive Framework members. Jurisdictions are not required to adopt the rules, but if they choose to do so they implement and administer them consistently with the agreed GloBE Model Rules and related guidance.","Answer",{"name":66,"@type":61,"acceptedAnswer":67},"Why do the rules need to be qualified for purposes of the Global Minimum Tax?",{"text":68,"@type":64},"Qualified rules are necessary to coordinate the agreed rule order across QDMTT, Qualified IIR, and the UTPR. Recognition of “qualified” status by implementing jurisdictions ensures priority and prevents over-taxation by turning off or adjusting the GloBE Rules in one jurisdiction where another has priority.",{"name":70,"@type":61,"acceptedAnswer":71},"How is the peer review used to recognize qualified status, and what is its purpose?",{"text":72,"@type":64},"Peer review provides a common assessment of the qualified rule status of IIR, UTPR and DMTT and eligibility for QDMTT Safe Harbour across each implementing jurisdiction. It supports consistency, efficiency, equal treatment among jurisdictions, and greater certainty for both jurisdictions and MNE Groups on where rules will apply.","https://schema.org",{"og:url":32,"og:type":75,"og:title":10,"og:site_name":45,"og:description":12},"article",{"robots":77,"canonical":32},"index,follow",{"doc_id":79,"site_id":7},375165,1791446505,{"code":4,"msg":82,"data":83},"success",[84,88,92,95,100,105,109,114,119,122,126],{"id":22,"doc_module":4,"doc_module_name":25,"category_name":85,"show_sort_weight":86,"slug":87},"Story & Novel",90,"story-novel",{"id":26,"doc_module":4,"doc_module_name":25,"category_name":89,"show_sort_weight":90,"slug":91},"Literature",80,"literature",{"id":33,"doc_module":4,"doc_module_name":25,"category_name":29,"show_sort_weight":93,"slug":94},70,"exam",{"id":96,"doc_module":4,"doc_module_name":25,"category_name":97,"show_sort_weight":98,"slug":99},5,"Comic",60,"comic",{"id":101,"doc_module":4,"doc_module_name":25,"category_name":102,"show_sort_weight":103,"slug":104},6,"Technology",50,"technology",{"id":55,"doc_module":4,"doc_module_name":25,"category_name":106,"show_sort_weight":107,"slug":108},"Healthcare",40,"healthcare",{"id":110,"doc_module":4,"doc_module_name":25,"category_name":111,"show_sort_weight":112,"slug":113},8,"Research & Report",30,"research-report",{"id":115,"doc_module":4,"doc_module_name":25,"category_name":116,"show_sort_weight":117,"slug":118},9,"Religion & Spirituality",20,"religion-spirituality",{"id":117,"doc_module":4,"doc_module_name":25,"category_name":120,"show_sort_weight":117,"slug":121},"World Cup","world-cup",{"id":123,"doc_module":4,"doc_module_name":25,"category_name":124,"show_sort_weight":123,"slug":125},10,"Lifestyle","lifestyle",{"id":127,"doc_module":4,"doc_module_name":25,"category_name":128,"show_sort_weight":96,"slug":129},19,"General","general",{"code":4,"msg":82,"data":131},{"doc_id":79,"user_id":132,"nickname":42,"user_avatar":11,"doc_module":4,"category_id":33,"category_name":29,"doc_title":10,"doc_description":12,"doc_content":133,"file_id":134,"file_url":135,"file_type":136,"file_size":137,"view_count":55,"is_deleted":4,"is_public":22,"is_downloadable":22,"audit_status":22,"page_count":101,"language":138,"language_code":8,"site_id":7,"html_lang":8,"table_of_contents":139,"faqs":140,"seo_title":141,"seo_description":12,"update_tm":142,"read_time":143,"preview_page_count":4},8796093062539,"Qualified Status under the Global  Minimum Tax – Questions and Answers  \nLast updated: January 2025  \n1. Are jurisdictions required to adopt the Global Minimum Tax? 2  \n2. Why do the rules need to be qualified for purposes of the Global Minimum Tax? 2  \n3. Why is the peer review used to recognise the qualified status? 3  \n4. How is the peer review conducted? 3  \n5. What is the purpose of the transitional qualification mechanism? 3  \n6. Which rules can be considered as qualified under the transitional qualification mechanism? 4  \n7. From when does the transitional qualified status apply? When does it stop? 5  \n8. Is it possible to prepare a self-certification based on draft legislation? 5  \n9. Can an implementing jurisdiction’s legislation lose the transitional qualified status? What are the consequences for MNE Groups? 5  \n10. Does the Inclusive Framework publish a compilation of jurisdictions’ legislation with transitional qualified status? 6  \n11. What are the next steps? 6  \n1. Are jurisdictions required to adopt the Global Minimum Tax?  \nThe Global Minimum Tax consists of an interlocking and coordinated system of domestic rules that are based on the GloBE Model Rules issued by the Inclusive Framework on BEPS (IF) in December 2021 and the associated commentary to those rules (Commentary and Administrative Guidance) . Once implemented into domestic law of each jurisdiction the rules operate together to ensure that MNE Groups are subject toa minimum level of tax on their excess profits in every jurisdiction where they operate.  \nThe October 2021 statement issued by members of the IF states that the Global Minimum Tax has the status of a common approach. This means that jurisdictions are not required to adopt the rules , but, if they choose to do so, they have agreed that they will implement and administer the rules in a way that is consistent with the outcomes provided for under the GloBE Model Rules and Commentary including any subsequent Administrative Guidance agreed by the IF.  \nIn addition, the common approach means that IF members accept the application of the rules applied by other IF members , including agreement as to rule order and the application of any agreed safe harbours.  \n2. Why do the rules need to be qualified for purposes of the Global Minimum Tax?  \nThe Global Minimum Tax results from the combined effect of three types of domestic charging provisions that apply in accordance with an agreed rule order:  \n􀂾 the Qualified Domestic Minimum Top-up Tax (QDMTT) which applies first, at the level of source jurisdiction, in respect of any low-taxed profits arising in that jurisdiction ,  \n􀂾 the Qualified Income Inclusion Rule (IIR) which applies in respect of remaining low-taxed profits. The IIR is applied first at the level of the Ultimate Parent Entity (UPE) of the MNE Group and then shifts to the next Intermediate Parent Entity (IPE) in the ownership chain in line with a top-down approach,  \n􀂾 the backstop rule (the UTPR) which applies at the level of any Constituent Entity within the MNE Group, to the extent low-taxed profits are not subject to a Qualified IIR.  \nThe agreed rule order is illustrated below.  \nAs illustrated in step 1 of this diagram , an MNE Group with low-taxed excess profits may be subject to a QDMTT imposed by the local jurisdiction on the excess profits of the Constituent Entities located in that jurisdiction. A payment of top-up tax under a QDMTT will be treated as fully creditable against another jurisdiction’s Qualified IIR or Qualified UTPR, as relevant. However, as illustrated at steps 2 and 3, where there is no QDMTT in the low-tax jurisdiction, an IIR will apply to impose top-up tax on the excess profits ; first at the level of the UPE and then at the level of an IPE further down the ownership chain if the UPE is located in a jurisdiction that has not adopted the GloBE Rules. Finally , the excess profits that are not  \nbrought into tax under a QDMTT or a Qualified IIR will fall within ","cbCaijnac9AXkRnM","https://ap.wps.com/l/cbCaijnac9AXkRnM","pdf",393991,"English","# Questions and Answers\n## Jurisdiction requirements and common approach\n## Why qualified rules are needed\n## Peer review for qualified status\n## Conduct of the peer review","[{\"question\":\"Are jurisdictions required to adopt the Global Minimum Tax?\",\"answer\":\"The Global Minimum Tax reflects a common approach among Inclusive Framework members. Jurisdictions are not required to adopt the rules, but if they choose to do so they implement and administer them consistently with the agreed GloBE Model Rules and related guidance.\"},{\"question\":\"Why do the rules need to be qualified for purposes of the Global Minimum Tax?\",\"answer\":\"Qualified rules are necessary to coordinate the agreed rule order across QDMTT, Qualified IIR, and the UTPR. Recognition of “qualified” status by implementing jurisdictions ensures priority and prevents over-taxation by turning off or adjusting the GloBE Rules in one jurisdiction where another has priority.\"},{\"question\":\"How is the peer review used to recognize qualified status, and what is its purpose?\",\"answer\":\"Peer review provides a common assessment of the qualified rule status of IIR, UTPR and DMTT and eligibility for QDMTT Safe Harbour across each implementing jurisdiction. It supports consistency, efficiency, equal treatment among jurisdictions, and greater certainty for both jurisdictions and MNE Groups on where rules will apply.\"}]","Qualified Status under the Global Minimum Tax - Questions and Answers | PDF",1790209556,15]