QDMTT implementation status in October 2026 is not a single global list — it is the sum of what each jurisdiction has enacted domestically, plus a separate, narrower list of what other tax authorities formally recognise as “qualified” for their own switch-off mechanisms. The clearest public version of that second list comes from HMRC’s Notice 2 on Pillar Two relevant territories and taxes, last updated 18 May 2026: it names only 22 jurisdictions whose domestic minimum top-up tax the UK currently treats as a Qualified Domestic Minimum Top-up Tax (QDMTT) and QDMTT Safe Harbour. Germany, France, the Netherlands, Ireland, Canada, Australia, South Korea and most of the EU-27 — all of which have had a domestic top-up tax in force since 2024 — are not on it.

That gap is the part of the QDMTT implementation story that compliance teams tend to miss, because it is easy to confuse “my country has enacted a QDMTT” with “my country’s QDMTT is recognised as qualified by the jurisdictions where my group also operates.” They are not the same question, and for a multinational group with an ultimate parent entity (UPE) or intermediate parent in the UK, or any other jurisdiction that publishes its own relevant-territories list, the difference can decide whether a subsidiary’s local top-up tax actually switches off the parent jurisdiction’s IIR or UTPR charge — or whether it doesn’t, at least not yet.

What a QDMTT Does, and Why Implementation Status Varies by Country

Under the OECD’s GloBE Model Rules (Pillar Two, BEPS Action 13’s companion framework), a constituent entity with an effective tax rate below 15% in a given jurisdiction triggers a top-up tax, ordinarily collected by the parent entity’s jurisdiction through an Income Inclusion Rule (IIR). A QDMTT lets the local jurisdiction collect that top-up tax itself, on its own low-taxed entities, before the IIR or UTPR of any other jurisdiction gets the chance to. Because the QDMTT is credited against the group’s residual top-up tax liability, a domestic minimum tax that is genuinely “qualified” neutralises the IIR/UTPR charge on that jurisdiction’s income entirely. One that isn’t recognised as qualified by the counterparty jurisdiction does not reliably do that — which is the mechanical reason the recognition gap below matters, not just a formality. We’ve covered the separate question of which transitional safe harbours shelter groups from full GloBE computations in our analysis of the OECD’s Pillar Two safe harbours.

The 22 Jurisdictions the UK Currently Lists as QDMTT-Qualified

HMRC’s Notice 2 — issued under the UK’s Multinational Top-up Tax and Domestic Top-up Tax regulations — sets out which territories’ domestic top-up taxes the UK treats as meeting the qualifying conditions (and, separately, the QDMTT Safe Harbour conditions) for the purpose of switching off a UK parent’s own top-up tax charge on that territory’s income. As of the version updated 18 May 2026, both lists are identical and cover 22 jurisdictions:

Switzerland sits in a different bucket again: HMRC’s notice lists a Swiss Income Inclusion Rule as qualified from 1 January 2025, but Switzerland does not appear on either the QDMTT or QDMTT Safe Harbour lists. Its domestic supplementary tax (“Ergänzungssteuer”), which Swiss authorities have applied since 1 January 2024, is not — per this specific UK notice — currently treated by HMRC as a QDMTT or a QDMTT Safe Harbour.

Why Germany, France, the Netherlands, Ireland, Canada and Australia Aren’t on It

This is the detail that doesn’t show up in most “which countries have Pillar Two” roundups, because it requires checking a specific counterparty list rather than the country’s own legislation. We checked HMRC’s Notice 2 directly for every G7 and major EU economy: Germany, France, the Netherlands, Ireland, Luxembourg, Belgium, Italy, Sweden, Austria, Canada, Australia and South Korea do not appear in either the QIIR section or the QDMTT/QDMTT Safe Harbour sections, as of the 18 May 2026 version. That is despite every one of those jurisdictions having a domestic top-up tax in force since financial years beginning on or after 31 December 2023 or 1 January 2024.

A few confirmed data points on what those jurisdictions actually have in place domestically, independent of their UK recognition status:

• Netherlands — the Minimum Tax Rate Act 2024 (Wet minimumbelasting 2024) entered into force on 31 December 2023, applies a 15% minimum rate, and uses the standard €750 million consolidated-revenue threshold, per the Dutch tax administration’s own guidance.
• Ireland — Revenue has set the first Pillar Two pay-and-file deadline at 30 June 2026, with a standard 15-month filing window (18 months for an entity’s first in-scope accounting period) and an elective QDTT group-filer mechanism so one entity can file for the whole domestic group.
• Canada — the Global Minimum Tax Act received royal assent on 20 June 2024, giving Canada its own IIR and domestic top-up tax mechanism as part of that statute.

None of this means those countries’ domestic top-up taxes are deficient — EU member states, for instance, implement Pillar Two through a shared directive with its own compliance architecture, and several large non-EU economies run their own peer-review processes with the OECD’s Inclusive Framework on a separate timeline from any single country’s bilateral recognition notice. What it means operationally is narrower and more concrete: a group with a UK parent (or a parent in any jurisdiction that publishes its own relevant-territories list) cannot assume that a subsidiary’s local QDMTT automatically switches off the parent jurisdiction’s top-up tax charge just because the subsidiary’s country has domestic Pillar Two legislation. That has to be checked against the parent jurisdiction’s own published list — and those lists are versioned and updated without much notice (HMRC’s has moved three times in under a year).

What to Check Before Your Next Fiscal Year-End

For each jurisdiction where the group has a constituent entity subject to a domestic top-up tax, three questions need separate answers, not one: does the local QDMTT exist and apply to this entity’s fiscal year; does the jurisdiction where the UPE (or the relevant intermediate parent) sits publish a relevant-territories or equivalent list, and does it include this jurisdiction; and if the local QDMTT is not yet recognised as qualified by that parent jurisdiction, what top-up tax exposure remains open under the IIR or UTPR in the interim. Groups with a Singaporean subsidiary have a documentation shortcut here: IRAS’s own e-Tax guide on the MTT and DTT states explicitly that Singapore’s Domestic Top-up Tax is designed to meet both the QDMTT and QDMTT Safe Harbour conditions, and that the Multinational Enterprise (Minimum Tax) Act obtained transitional qualified status with effect from 1 January 2025 — language most other jurisdictions’ guidance does not spell out this directly.

Does having a domestic top-up tax automatically mean it’s a “QDMTT”?

No. A domestic minimum top-up tax only functions as a true QDMTT once it is recognised as meeting the OECD’s qualifying conditions — either through the Inclusive Framework’s peer-review process or through a counterparty jurisdiction’s own published recognition, such as HMRC’s Notice 2. Many jurisdictions’ domestic legislation is drafted to meet those conditions, but recognition and legislation move on different timelines.

What happens if a subsidiary’s QDMTT isn’t recognised by the parent jurisdiction?

The parent jurisdiction’s own IIR or UTPR mechanism can still apply a top-up charge on that low-taxed income, because the local tax hasn’t been confirmed to neutralise the GloBE calculation for that jurisdiction’s purposes. Whether that produces double taxation in practice depends on each jurisdiction’s specific credit and safe harbour rules — this is a case for the group’s Pillar Two advisers, not a generic answer.

How often do these recognition lists change?

HMRC’s Notice 2 alone has been updated multiple times since its first publication on 24 July 2025, most recently (as reviewed for this article) on 18 May 2026. Treat any snapshot, including this one, as needing a recheck against the current published notice before relying on it for a specific filing position.

Where is Japan’s QDMTT in this timeline?

HMRC’s notice lists Japan’s QDMTT as effective from 1 April 2026 — later than the 1 January 2025 wave that covers most of the other 21 jurisdictions on the list, reflecting Japan’s own fiscal-year-based phase-in of its domestic minimum top-up tax rules.

This article is informational and does not constitute tax advice for any specific group or transaction. Figures and dates are drawn from the official sources linked above and reflect their status as of the versions reviewed; always confirm against the current published notice before relying on a filing position. See also our Pillar Two Statement Country Tracker for which jurisdictions have made the OECD’s political commitment to Pillar Two in the first place.