Key implementation point
GILTI is not GloBE-compliant. US MNE groups face IIR/UTPR exposure in other jurisdictions despite no US Pillar Two enactment.
Implementation detail
- 01 The US has not enacted Pillar Two IIR, UTPR or QDMTT as of 2026.
- 02 GILTI (Global Intangible Low-Taxed Income) is a US minimum tax on offshore income but does not conform to GloBE model rules.
- 03 GILTI effective rates do not qualify as a QDMTT under OECD rules — US GILTI is not a qualified top-up tax.
- 04 US political landscape has made Pillar Two enactment unlikely in the near term.
- 05 The UTPR (applied by other jurisdictions to US MNE groups with low-taxed entities) remains a major diplomatic flashpoint.
- 06 US Treasury has engaged in OECD discussions and issued statements on the UTPR, but legislative action has stalled.
- 07 US MNE groups are caught by other countries' IIR/UTPR rules even though the US has not enacted equivalent measures.
Official sources & further reading
Track United States 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 →