The global minimum tax in India is the OECD Pillar Two regime that puts a floor of 15% on the effective tax rate that large multinational groups pay in each country they operate in. It applies to groups with consolidated revenue of at least 750 million euros, roughly 6,750 crore rupees, in at least two of the four preceding years. India has not yet written Pillar Two into the Income-tax Act, 1961, so it does not collect the top-up tax itself, but Indian companies inside in-scope groups are already affected because other countries collect it and India’s accounting standards now carry Pillar Two disclosure rules.
This article sets out how the global minimum tax works, which companies it covers in India, where India stands on enacting it, and the AS 22 and Ind AS 12 duties that already apply.
Pillar Two is the second half of the OECD and G20 two-pillar deal that more than 135 countries signed on to. Its target is a familiar one: large groups that book profit in low-tax or no-tax jurisdictions and pay very little on it. The mechanism is a 15% minimum, tested country by country, with a top-up charge wherever the group falls short.
The point that trips up most readers is the split between two sets of rules. The tax rules, which decide who pays the top-up and to whom, are not yet part of Indian law. The accounting rules, which decide what a company must disclose about its Pillar Two exposure, are already notified, and they landed for non-Ind-AS companies as recently as March 2026. A finance team can be outside the Indian charge and still inside the Indian disclosure net at the same time.
How the global minimum tax works under OECD Pillar Two
The global minimum tax under OECD Pillar Two sets a 15% floor on the effective tax rate that a large multinational group pays in each country where it does business. If the group’s effective rate in a country comes out below 15%, a top-up tax collects the difference. The rules that do this are called the Global Anti-Base Erosion Rules, or GloBE Rules, and they were published by the OECD Inclusive Framework in December 2021.
The design answers a specific problem. For years, groups shifted profit into jurisdictions that taxed it lightly, using structures such as the Double Irish and Dutch Sandwich, and no single country could stop it alone. Pillar Two changes the incentive. If a country chooses not to tax a group’s profit up to 15%, another country in the chain gets to collect the shortfall instead. The low rate no longer buys the group a lower bill; it just moves the revenue to a different treasury.
The effective rate here is not the headline corporate rate. It is a GloBE-specific calculation: the covered taxes a group actually pays in a country, divided by its GloBE income in that country, both worked out under the rules’ own definitions. A company can carry a 25% statutory rate on paper and still show a GloBE effective rate under 15% once holidays, deductions and timing differences are stripped in. That gap is where the top-up bites, and it is why the calculation matters more than the rate card.
Scope is set by size. The rules reach groups with annual consolidated revenue of at least 750 million euros in at least two of the four preceding fiscal years, the same threshold used for country-by-country reporting. Everything below that line sits outside Pillar Two entirely. This is a regime built for the largest groups, and the wider shift in how global tax is coordinated runs through it.
What do QDMTT, IIR and UTPR actually do?
The top-up tax is charged through three rules that run in a fixed order. A Qualified Domestic Minimum Top-up Tax, or QDMTT, lets the country where the low-taxed profit arises collect the top-up first and keep it. An Income Inclusion Rule, or IIR, lets the parent company’s country charge the top-up on a low-taxed foreign subsidiary. An Undertaxed Profits Rule, or UTPR, is the backstop: it allocates any remaining top-up to other countries by denying deductions, when no IIR has already mopped it up.
The order is deliberate and it decides who gets the money. QDMTT ranks first, so a country that enacts one keeps the revenue from its own low-taxed entities rather than surrendering it. If it does not, the IIR in the parent’s country takes the profit next. The UTPR only comes into play for what slips through both. For a group, the practical effect is that the same 15% shortfall gets collected once; the fight is between governments over which one collects it.
This ordering is the reason a country’s decision to stay out of Pillar Two does not protect the profit earned there. It only changes the destination of the tax.
How does the substance-based carve-out reduce the top-up tax?
The substance-based income exclusion carves out a slice of profit from the top-up calculation, tied to real activity in a country. It removes a set percentage of the group’s payroll costs and of the carrying value of its tangible assets, such as plant, machinery and buildings, from the income that the top-up tax can reach. Profit backed by people and physical assets is treated as genuine local activity rather than shifted profit.
The percentages settle at 5% of payroll and 5% of tangible assets in the steady state, with higher figures during a ten-year transition that step down each year. For a labour-heavy or asset-heavy operation, the carve-out can be large. An Indian manufacturing unit with a big workforce and a plant on its books may find that most of its profit falls inside the exclusion, so even a sub-15% effective rate produces little or no top-up. A capital-light, high-margin operation, by contrast, gets a much smaller shield and feels the top-up far sooner.
How the Pillar Two top-up tax is charged
Which groups are in scope, the 15% test, and the fixed order in which the shortfall is collected
Step 1 – In scope?
Consolidated group revenue of at least 750 million euros
Measured in at least 2 of the 4 preceding fiscal years (about 6,750 crore rupees). Smaller and purely domestic groups are out.
Step 2 – The 15% test
Is the group’s effective rate in a country below 15%?
The GloBE effective rate is covered taxes divided by GloBE income, not the headline statutory rate. A shortfall triggers a top-up.
Before the top-up: the substance-based income exclusion removes 5% of payroll costs and 5% of tangible assets (higher in the transition years) from the profit the top-up can reach. This shields labour-heavy and asset-heavy operations.
The order of charge (the shortfall is collected once)
1
QDMTT – the source country
A qualified domestic minimum top-up tax lets the country where the profit arises collect the top-up and keep it. India has none.
2
IIR – the parent’s country
The income inclusion rule lets the parent company’s country charge the top-up on a low-taxed foreign subsidiary.
3
UTPR – the backstop
The undertaxed profits rule allocates any remaining top-up to other countries, usually by denying deductions.
India today
No QDMTT, IIR or UTPR sits in the Income-tax Act, 1961. So the top-up on low-taxed Indian profit is currently collected abroad, at the parent’s level, under another country’s IIR.
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Which companies does the global minimum tax apply to in India?
The global minimum tax applies to Indian companies that are part of a multinational group meeting the 750 million euro revenue threshold, whether the group is headed in India or abroad. It does not apply to purely domestic Indian companies, and it does not apply to smaller groups that fall under the threshold. Standing alone, an Indian company’s own size is not the test; what matters is the consolidated revenue of the whole group it belongs to.
Two broad populations are caught. The first is Indian-headquartered groups large enough to cross the threshold, whose overseas subsidiaries and Indian operations both come into the calculation. The second, and the larger population in practice, is Indian subsidiaries and joint ventures of foreign multinational groups, where the parent sits in a country that has already brought in Pillar Two. An Indian arm of a European or Korean group can be a constituent entity even if its own turnover is modest, because the threshold is tested at group level. Cross-border groups already managing outbound structuring from India will recognise the same population that Pillar Two now reaches.
Being in scope is not the same as owing top-up tax. A constituent entity is inside the system, has to be included in the group’s calculations, and may have to file or feed into a GloBE Information Return. Whether any top-up is actually due depends on the group’s effective rate in India, which for most normally taxed Indian companies sits above 15%. The compliance obligation is triggered by scope; the cash cost is triggered only by a shortfall.
The 750 million euro threshold, measured over four years
The threshold is consolidated group revenue of at least 750 million euros in at least two of the four fiscal years immediately preceding the tested year. Converted at a rough exchange rate, that is in the region of 6,750 crore rupees, though the euro figure is the one that governs. The two-of-four test stops a group from dropping in and out of the rules on a single year’s dip or spike in turnover.
This is the same threshold India already uses for country-by-country reporting under Section 286 of the Income-tax Act, 1961, where the domestic filing trigger is set at 6,400 crore rupees of consolidated group revenue, raised from 5,500 crore with effect from April 2021 to line up with the 750 million euro figure. Groups that already prepare a CbC report have, in effect, done the threshold test before. The Pillar Two population in India maps closely onto the CbC population, which is why the reporting infrastructure built for CbC is the natural base for GloBE compliance.
Has India enacted Pillar Two, and what happens until it does?
India has not enacted Pillar Two. As of the middle of 2026, there is no QDMTT, IIR or UTPR in the Income-tax Act, 1961, and the Union Budgets through this period did not introduce one. India helped negotiate the two-pillar solution and remains part of the Inclusive Framework, but it has held back from writing the GloBE Rules into domestic law, unlike the European Union member states, the United Kingdom, and a growing list of Asian jurisdictions that have already switched their rules on.
Here is what that means in cash terms. When an Indian operation inside a foreign-parented group is taxed below 15% on its GloBE income, the top-up on that shortfall does not stay in India. Because India has no QDMTT, the parent’s country collects it under its IIR instead. The profit is Indian, the low rate is Indian, but the extra tax goes abroad. That is the revenue-leakage argument, and it is the strongest reason for India to bring in a QDMTT of its own: a domestic top-up would keep that money at home without raising the effective burden on the group beyond the 15% it now owes somewhere regardless.
Whether India moves, and when, is a Budget question worth watching. A QDMTT is the most likely first step, because it captures revenue that is otherwise leaving the country while leaving the group’s overall Pillar Two bill unchanged. India has form for acting unilaterally on cross-border tax when a global consensus was slow, as it did with the equalisation levy on digital and online marketplace transactions before agreeing to withdraw it as part of the two-pillar deal. Until a domestic rule arrives, though, the Indian charge is simply absent, and the action sits overseas.
Why an Indian company’s effective tax rate can fall below 15%
An Indian company can breach the 15% GloBE floor even though the standard corporate rate looks comfortably higher, because the GloBE effective rate is computed on a different base and several Indian regimes cut the tax actually paid. A domestic company opting into Section 115BAA of the Income-tax Act, 1961 pays about 25.17% once surcharge and cess are added, which is well clear of 15%. The problem is not the ordinary case. It is the range of situations where statutory reliefs pull the real rate down.
Several features of Indian corporate tax can produce a GloBE rate below the floor. New manufacturing companies that opted into Section 115BAB pay a concessional 15% base rate, which after the GloBE calculation can land at or under the line. Units in Special Economic Zones enjoy profit-linked deductions that can take their effective tax to near zero during the holiday period. Weighted deductions, accelerated depreciation and other timing differences widen the gap between book profit and taxed profit. Each of these was designed to attract or reward investment, and each can, on the GloBE math, look like undertaxed profit.
The catch for tax teams is that the GloBE effective rate does not track any single line in the return. It divides covered taxes by GloBE income, both defined by the rules, so a company has to rebuild the number rather than read it off. A concessional-rate company under Section 115BAA or 115BAB cannot assume it is safe just because its statutory rate is 15% or more; the deductions sitting underneath can still drag the GloBE rate down. The substance-based carve-out described earlier is what often saves an Indian manufacturer here, because the payroll and asset exclusion removes much of the profit before the top-up is worked out.
There is a hard point worth stating plainly. A company can owe zero extra tax in India, be fully compliant with Indian law, and still generate a Pillar Two top-up that a foreign treasury collects. The shortfall is measured against a global standard, not against Indian rules, and Indian incentives do not shelter it from that standard.
What do the AS 22 and Ind AS 12 Pillar Two amendments require?
The AS 22 and Ind AS 12 amendments require companies to do two things: skip deferred tax accounting for Pillar Two taxes, and disclose their Pillar Two exposure instead. The accounting profession worried that groups would otherwise have to model deferred tax assets and liabilities for a top-up regime that is complex and still rolling out country by country. The fix, adopted globally and then in India, was a mandatory exception from that deferred tax work, paired with disclosure so that readers of the accounts are not left blind.
India applied the fix twice, because it runs two accounting frameworks. Larger and listed companies report under Indian Accounting Standards, where the relevant standard is Ind AS 12, Income Taxes. Companies outside the Ind AS net report under the older Accounting Standards, where the equivalent is AS 22, Accounting for Taxes on Income. Each needed its own amendment to carry the Pillar Two exception, and the two arrived nearly three years apart.
What did the Companies (Accounting Standards) Amendment Rules, 2026 change in AS 22?
The Companies (Accounting Standards) Amendment Rules, 2026, notified by the Ministry of Corporate Affairs through G.S.R. 169(E) dated 10 March 2026, added a Pillar Two exception and a set of disclosures to AS 22. A new paragraph 2A creates the exception: a company shall neither recognise nor disclose deferred tax assets and liabilities arising from taxes under Pillar Two legislation, including a qualified domestic minimum top-up tax. The company simply leaves that deferred tax out of its accounts.
Four disclosure paragraphs sit alongside the exception. Paragraph 32A requires the company to state that it has applied the exception. Paragraph 32B requires it to disclose, separately, the current tax expense relating to Pillar Two income taxes. Paragraphs 32C and 32D deal with the window where Pillar Two law has been enacted somewhere the group operates but has not yet taken effect, and they call for known or reasonably estimable information about that coming exposure, including the jurisdictions involved and an indication of the effect on the group’s rate, with ranges allowed where a precise figure cannot be given.
Two practical points close this out. First, small and medium-sized companies get relief from the heavier forward-looking disclosures in paragraphs 32C and 32D, though the exception and the core disclosure still apply. Second, the timing splits: paragraph 2A and paragraph 32A apply immediately and retrospectively on the amendment’s issue, while paragraphs 32B to 32D apply for annual reporting periods beginning on or after 1 April 2025. The net effect is that the accounting gets simpler, because the deferred tax modelling drops away, but the disclosure burden goes up.
How does the AS 22 change compare with the 2023 Ind AS 12 amendment?
The Ind AS 12 amendment did the same job three years earlier for Ind AS companies. The Companies (Indian Accounting Standards) Amendment Rules, 2023, notified on 31 March 2023 and effective from 1 April 2023, inserted the temporary mandatory exception into Ind AS 12, so that companies reporting under Ind AS also neither recognise nor disclose deferred tax on Pillar Two taxes, and disclose their exposure instead. It tracked the International Accounting Standards Board’s May 2023 change to IAS 12, which is why India’s larger listed groups were already handling this in their accounts well before the AS 22 change appeared.
So the substance is the same across both frameworks; what differs is which companies fall under which, and when the rule reached them. A listed or larger company on Ind AS has been applying the exception since the 2023 financial year. A smaller private company on AS 22 comes to it now, under the 2026 rules. The label calls the exception temporary, but neither the Indian amendments nor the IASB original set a sunset date, so it stays in place until the standard-setters decide the top-up regime is stable enough to unwind it.
The reason both amendments matter even though India has not enacted Pillar Two is worth repeating in the accounting context. An Indian company in a foreign-parented group faces Pillar Two taxes at the group level today, levied by countries that have switched their rules on. The disclosure paragraphs bite on that foreign exposure. A company can therefore have nothing to charge under Indian tax law and still have something to disclose under Indian accounting law.
India’s two Pillar Two accounting amendments
Same substance, different framework and timing: AS 22 for non-Ind-AS companies, Ind AS 12 for listed and larger ones
ItemAS 22 (2026)Ind AS 12 (2023)
ItemWho reports under it
AS 22 (2026)Companies on the older Accounting Standards (mostly private and smaller companies)
Ind AS 12 (2023)Companies on Indian Accounting Standards (listed and larger companies)
ItemNotification
AS 22 (2026)Companies (Accounting Standards) Amendment Rules, 2026; G.S.R. 169(E) dated 10 March 2026
Ind AS 12 (2023)Companies (Indian Accounting Standards) Amendment Rules, 2023
ItemEffective
AS 22 (2026)Paragraphs 2A and 32A immediate and retrospective; 32B to 32D for periods beginning on or after 1 April 2025
Ind AS 12 (2023)Effective 1 April 2023
ItemThe exception (same in both)
AS 22 (2026)Neither recognise nor disclose deferred tax for Pillar Two taxes, including a QDMTT
Ind AS 12 (2023)Neither recognise nor disclose deferred tax for Pillar Two taxes, including a QDMTT
ItemDisclosures
AS 22 (2026)Apply the exception (32A); current Pillar Two tax shown separately (32B); pre-effective-date exposure (32C to 32D)
Ind AS 12 (2023)Apply the exception and disclose Pillar Two exposure, tracking the IASB change to IAS 12
ItemRelief for smaller companies
AS 22 (2026)Small and medium-sized companies need not apply paragraphs 32C and 32D
Ind AS 12 (2023)Applies to companies already on Ind AS; no SMC carve-out of this kind
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What must Indian companies do to comply now?
In-scope Indian companies should map their group’s effective tax rate country by country, quantify how far Indian incentives pull that rate down, build the data to support a GloBE Information Return, and make the accounting disclosures that already apply. None of this waits on India enacting Pillar Two, because the group-level exposure and the disclosure duties exist regardless. The work is data-heavy and it sits across tax, accounting and reporting functions at once.
A workable sequence looks like this. First, confirm scope by running the two-of-four-years revenue test at group level, which most groups can lift straight from their country-by-country reporting under Section 286 of the Income-tax Act, 1961. Next, compute the GloBE effective rate for the Indian jurisdiction, rebuilding covered taxes over GloBE income rather than reading the statutory rate, and flag any entity whose reliefs, SEZ deductions or concessional rates threaten the 15% line. Then test whether a transitional safe harbour removes India from top-up exposure for the early years. Finally, prepare the AS 22 or Ind AS 12 disclosures and brief the audit committee on the numbers.
The transitional CbCR safe harbours are the near-term relief most groups will reach for. For the first years of the regime, a jurisdiction can be treated as meeting the standard, with no top-up, if it passes one of three tests built on country-by-country data: a de minimis test for small revenue and profit, a simplified effective rate test against a transition rate that rises over the initial years, or a routine-profits test measured against the substance carve-out. Getting these right depends on clean CbC data, which is exactly why the reporting groups already file becomes the backbone of the exercise.
Worth flagging for professionals: the skills this creates demand for are cross-border and specialised, from GloBE calculations to safe-harbour analysis, and some finance professionals build toward international credentials such as the US Enrolled Agent qualification to work on this kind of mandate. For most Indian companies, though, the immediate need is internal readiness: the data systems, the effective-rate model and the disclosures, in place before the group’s reporting deadline rather than after it.
How does Pillar Two interact with MAT, tax treaties and transfer pricing in India?
Pillar Two sits on top of India’s existing tax rules rather than replacing them, and it interacts with three in particular: minimum alternate tax, tax treaties and transfer pricing. None of these goes away because of the global minimum tax. Each continues to apply on its own terms, and each affects, or is affected by, the GloBE calculation in a different way.
Minimum alternate tax under Section 115JB of the Income-tax Act, 1961 already imposes a floor of its own, charging companies about 15% on book profits where their normal tax comes out lower. That looks close to Pillar Two, but the two are not the same. MAT is charged on book profit under Indian rules, while the GloBE rate is covered taxes over GloBE income under the rules’ definitions, so a company can satisfy MAT and still show a GloBE rate below 15%. MAT paid does count as a covered tax and lifts the GloBE numerator, which helps, yet it does not guarantee the group clears the floor in India. Tax treaties, for their part, do not shield a group from the top-up, because the IIR and UTPR are charged by a country on its own taxpayers rather than on the foreign entity the treaty protects.
Transfer pricing is the one that becomes more, not less, important. Pillar Two starts from where profit is booked across a group, and transfer pricing is what decides that allocation in the first place. A transfer pricing adjustment that moves profit between countries moves GloBE income with it, and can push a jurisdiction over or under the 15% line. Groups that treated their intercompany pricing as a compliance formality now have a second reason to get it right, because the same numbers feed the global minimum tax. The base-erosion structures Pillar Two was built to neutralise are the ones transfer pricing rules have long policed, and the two regimes now work the same seam from different angles.
Frequently asked questions
What is the global minimum tax?
The global minimum tax is OECD Pillar Two, a set of rules called the GloBE Rules that require large multinational groups to pay an effective tax rate of at least 15% in every country they operate in. Where the rate falls short, a top-up tax collects the difference. It applies to groups with consolidated revenue of at least 750 million euros.
Does the global minimum tax apply in India?
It applies to Indian companies that belong to an in-scope multinational group, but India has not itself enacted the charging rules. As of mid-2026 there is no domestic top-up tax in the Income-tax Act, 1961, so any top-up on low-taxed Indian profit is currently collected abroad by the parent company’s country, not by India.
What is the 750 million euro threshold in rupees?
Roughly 6,750 crore rupees, though the governing figure is the euro amount, not the rupee conversion. The group must have hit that consolidated revenue in at least two of the four fiscal years before the tested year. It is the same threshold India uses for country-by-country reporting.
What is a QDMTT?
A Qualified Domestic Minimum Top-up Tax is a top-up a country charges on its own low-taxed entities, so that it collects the Pillar Two shortfall itself instead of ceding it to another country. It ranks first in the order of charge. India has not introduced one, which is why top-up on Indian profit currently goes abroad.
What is the difference between the IIR and the UTPR?
The Income Inclusion Rule lets a parent company’s country charge the top-up on its low-taxed foreign subsidiaries. The Undertaxed Profits Rule is the backstop that allocates any remaining top-up to other countries, usually by denying deductions, when no IIR has collected it. The IIR applies first; the UTPR catches what the IIR does not.
Has India introduced a QDMTT?
No. As of mid-2026 India has not enacted a QDMTT, an IIR or a UTPR. A QDMTT is widely seen as the likely first step if India does move, because it would keep in India the top-up that is currently collected overseas, without increasing the group’s overall Pillar Two bill.
If India has not enacted Pillar Two, why do Indian companies care?
Because the exposure is at group level. An Indian company inside a foreign-parented group faces Pillar Two taxes levied by the parent’s country, and India’s accounting standards now require disclosure of that exposure. A company can owe no top-up under Indian tax law and still have to make Pillar Two disclosures under AS 22 or Ind AS 12.
Can a company taxed at 25.17% still owe top-up tax?
Yes, in specific situations. The 15% test uses the GloBE effective rate, which is covered taxes over GloBE income under the rules’ own definitions, not the headline statutory rate. Deductions, SEZ holidays, concessional rates and timing differences can pull the GloBE rate below 15% even where the statutory rate is higher.
Do SEZ units face Pillar Two top-up tax?
They can. Special Economic Zone units enjoy profit-linked deductions that can take their effective tax close to zero during the holiday, which is exactly the kind of low rate Pillar Two tops up. The substance-based carve-out for payroll and tangible assets often reduces the exposure for units with real local activity, but it does not always remove it.
What is the substance-based income exclusion?
It is a carve-out that removes a percentage of a group’s payroll costs and tangible asset value from the profit the top-up can reach. The percentages settle at 5% each in the steady state, higher during a ten-year transition. It shields profit backed by people and physical assets, which helps labour-heavy and asset-heavy Indian operations most.
What are the transitional CbCR safe harbours?
They are temporary reliefs that treat a jurisdiction as compliant, with no top-up, for the early years of Pillar Two if it passes one of three tests built on country-by-country reporting data: a de minimis test, a simplified effective rate test, or a routine-profits test. They give groups time to build full GloBE systems while relying on data they already report.
What did the Companies (Accounting Standards) Amendment Rules, 2026 change?
They amended AS 22 to add the Pillar Two deferred tax exception and related disclosures for companies that report under the Accounting Standards rather than Ind AS. The amendment was notified through G.S.R. 169(E) dated 10 March 2026 and inserted new paragraphs 2A and 32A to 32D into AS 22.
What is the AS 22 deferred tax exception for Pillar Two?
Under the new paragraph 2A, a company neither recognises nor discloses deferred tax assets and liabilities arising from Pillar Two taxes, including a qualified domestic minimum top-up tax. It removes the requirement to model deferred tax for the top-up regime, and replaces it with disclosure of the exposure.
When do the AS 22 disclosures apply?
The exception in paragraph 2A and the disclosure in paragraph 32A apply immediately and retrospectively on the amendment’s issue. The further disclosures in paragraphs 32B to 32D apply for annual reporting periods beginning on or after 1 April 2025. Small and medium-sized companies are relieved from the forward-looking disclosures in paragraphs 32C and 32D.
How is AS 22 different from the Ind AS 12 amendment of 2023?
The substance is the same; the difference is which companies and when. Ind AS 12 was amended by the Companies (Indian Accounting Standards) Amendment Rules, 2023, effective 1 April 2023, for companies reporting under Ind AS. AS 22 was amended in 2026 for companies reporting under the older Accounting Standards. Larger and listed groups have handled this since 2023; smaller companies come to it now.
What is a GloBE Information Return?
It is the standardised return through which an in-scope group reports the data needed to apply the GloBE Rules, including its jurisdiction-by-jurisdiction effective rates and any top-up tax. It is the central compliance filing under Pillar Two, and building the data to support it is a large part of what in-scope Indian companies must prepare for.
Does Pillar Two replace transfer pricing?
No. Transfer pricing decides how profit is allocated across a group’s countries, and Pillar Two then tests the rate on that allocated profit. A transfer pricing adjustment shifts GloBE income between jurisdictions and can change where a top-up arises, so accurate transfer pricing matters more under Pillar Two, not less.
References
Statutes and rules
- Income-tax Act, 1961: Sections 115BAA, 115BAB, 115JB (MAT) and 286 (country-by-country reporting). Income Tax Department
- Companies (Accounting Standards) Amendment Rules, 2026: G.S.R. 169(E) dated 10 March 2026 (amending AS 22, Accounting for Taxes on Income).
- Companies (Indian Accounting Standards) Amendment Rules, 2023: notified 31 March 2023, effective 1 April 2023 (amending Ind AS 12, Income Taxes).
Official and institutional sources
- OECD, Global Anti-Base Erosion Model Rules (Pillar Two), 2021, the GloBE Rules. OECD global minimum tax
- OECD, Minimum Tax Implementation Handbook (Pillar Two). OECD Handbook (PDF)
Statutory and notification URLs are live-verified at fact-check; where a government page is unreachable, an authoritative alternative is substituted.
Disclaimer
This article is for informational and educational purposes only and does not constitute legal, tax or accounting advice. Pillar Two, its Indian implementation and the accounting standards referenced here are evolving; the position stated is as of the date of writing. Companies should take professional advice specific to their group structure and facts before acting.
