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Japan Planning to Implement Pillar 2 QDMTT and UTPR in 2026

27 December 2024

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Proposed Changes

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Japan

Japan's ruling coalition has agreed on tax reform guidelines for fiscal year 2025. Among other things, this includes plans to implement the Pillar 2 qualified domestic minimum top-up tax (QDMTT) and undertaxed payment/profits rule (UTPR) with effect from 1 April 2026. Japan has already implemented the Pillar 2 income inclusion rule (IIR) with effect from 1 April 2024. Additional details will be published once available.