Key implementation point
Not yet enacted. India's new manufacturing incentive (15% rate) is a key policy priority — Pillar Two QDMTT would reduce incentive value.
Implementation detail
- 01 India has not enacted Pillar Two legislation as of 2026.
- 02 India is a member of the OECD Inclusive Framework and participated in the Two-Pillar Solution.
- 03 India has concerns about UTPR impacting FDI flows, and has engaged diplomatically on implementation.
- 04 India's DDT (Dividend Distribution Tax) replacement and its corporate tax rate (22% standard, 15% for new manufacturing) would require GloBE analysis.
- 05 CBDT (Central Board of Direct Taxes) has not published formal GloBE consultation as of 2026.
- 06 India-headquartered MNE groups have foreign low-taxed entities that may be subject to IIR in jurisdictions that have enacted.
- 07 Expectation is India will eventually enact QDMTT to protect its tax base, but timeline unclear.
Track India rules against your live MNE
In Pillar2OS you can pull this jurisdiction's rules directly into your entity structure — automatically calculating top-up positions, flagging QDMTT obligations, and tracking rule changes as they happen across all your operating countries.
See it in the sandbox →