15% Minimum Tax for International Companies: Requirements and Conditions in 2026
What Is the Global Minimum Tax?
In 2026, the global minimum tax remains a key instrument in international tax regulation. The "Pillar Two" rules, developed under the auspices of the OECD and the G20, are designed to ensure that large multinational corporate groups pay income tax at an effective rate of at least 15% in every jurisdiction where they operate.
This mechanism aims to reduce incentives for shifting profits to low-tax countries and to increase the transparency of international corporate structures. It should be noted that the 15% rate is not a universal corporate tax rate applicable to all companies; rather, the rules apply to specific groups and entail a specialized method for calculating the tax burden.
Which Companies Fall Under Pillar Two?
The primary criterion for the application of these rules is that a multinational group must have an annual consolidated revenue of at least €750 million. Typically, this threshold must be met in at least two of the four fiscal years preceding the period under review.
The rules apply to groups that operate in more than one jurisdiction and prepare consolidated financial statements. This encompasses not only parent companies but also the subsidiaries and permanent establishments that are part of the group.
In some countries, Pillar Two requirements may also extend to large groups that operate exclusively within the domestic market; the application of such provisions depends on national legislation.
Certain entities—including specific government bodies, international organizations, pension funds, and investment funds—may be excluded from the scope of these rules, provided that certain conditions are met.
How Is the Minimum Tax Calculated?
The effective tax rate is determined based on the specific Pillar Two rules, taking into account adjusted profit and the relevant taxes paid in each jurisdiction. If the calculated tax rate falls below 15%, an obligation to pay an additional tax may arise.
The mechanism includes several key instruments:
- QDMTT (Qualified Domestic Minimum Top-up Tax) — a domestic supplementary tax that allows a country to levy tax on low-taxed profits generated within its territory.
- IIR (Income Inclusion Rule) — a rule under which a top-up tax is typically levied at the level of the parent company.
- UTPR (Undertaxed Profits Rule) — a supplementary mechanism applied under specific conditions if the tax has not been fully collected through other rules.
Calculations may take into account statutory exemptions, including those related to personnel costs and tangible assets.
What changes for international business in 2026
Companies subject to "Pillar Two" must assess their tax burden across all countries where they operate, prepare the necessary data, and verify their registration and reporting obligations. The quality of financial information, consistency of data across business units, and adherence to filing deadlines are of critical importance.
In 2026, this international system continues to evolve, with the OECD issuing further clarifications and simplification measures. Furthermore, agreed-upon amendments provide for special conditions for certain groups, including those linked to jurisdictions with recognized equivalent tax regimes. Therefore, when analyzing obligations, it is essential to consider not only the general rules but also current international agreements and national regulations.
International tax support with IT-OFFSHORE
IT-OFFSHORE assists entrepreneurs with registering companies abroad, selecting jurisdictions, corporate structuring, and preparing documentation for international business projects. The company’s specialists provide consultations on choosing a jurisdiction for registration, organizing corporate structures, and interacting with financial institutions, helping clients navigate tax and regulatory requirements as they expand their businesses internationally.
