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  • Pillar 2
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Pillar 2

2024 Was the Council Directive (EU) 2022/2523 implemented into the local legislation?  Did the local legislation implement IIR?  Did the local legislation implement UTPR?  Did the local legislation implement QDMTT?  What tax types qualify as covered taxes under the GloBE rules? Does the local law include any significant difference compared to the Directive? 
Albania  N/A New Law effective from January 2024 is partially aligned with the Directive.
Austria corporate income tax (Körperschaftsteuer)
Bosnia and Herzegovina N/A N/A N/A N/A N/A
Bulgaria The covered taxes of a constituent entity shall extend to: 1. the expenses charged for taxes with respect to the profit and income of the constituent entity; a tax upon profit distribution or what qualifies as such, as well as a tax on non-business expenses under an eligible profit distribution tax system; alternative taxes imposed instead of corporate tax; a tax on retained earnings and equity, including on multiple components based on profit, income, and equity. 
Croatia There is no distinction between local law and the provisions of the Directive.  
Czech Republic Taxes reported in the entity's financial statements based on its income or profit, i.e. CIT including capital gain tax, windfall tax, and adjusted deferred tax  
Estonia  N/A  N/A  N/A  N/A  N/A
Germany  corporate and trade tax as well as the solidarity surcharge, capital gains tax No, but the option for the national supplementary tax was taken, which applies if domestic business units of a foreign group are subject to an effective tax of less than 15%.  
Greece N/A N/A N/A N/A N/A
Hungary  Corporate income tax, local business tax, innovation contribution, Robin Hood tax  Hungarian legislation allows taxpayers to compute their GloBE tax liability based on the Hungarian Accounting Standards.
Kazakhstan N/A N/A N/A N/A N/A
Kosovo N/A N/A N/A Corporate Income Tax 5%
Kyrgyzstan N/A  N/A  N/A  N/A  N/A 
Latvia N/A  N/A  N/A  N/A  N/A 
Lithuania N/A N/A N/A N/A N/A
Moldova  N/A  N/A  N/A  N/A  N/A
Montenegro  N/A  N/A  N/A  N/A  N/A
North Macedonia    
Poland  N/A  N/A  N/A  N/A  N/A
Romania  Corporate Income Tax or any substitute, taxes on distributed profits, payments qualifying as profit distributions, and non-business expenses, taxes on retained earnings and corporate equity.  Romania must notify the EC of the election of the QDMTT within 4 months following the adoption of the domestic law, meaning by end of April 2024.
Serbia  N/A  N/A  N/A  N/A  N/A
Slovakia Tax declared in financial statements of constituent entity in relation to its income (profit).
Slovenia Income tax 
Ukraine N/A  N/A  N/A  N/A  N/A 
Uzbekistan N/A  N/A  N/A  N/A  N/A