Pillar Two Tools & Analysis

Domestic Pillar Two Implementation

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Latest Pillar 2 Developments

June 30, 2025: Kuwait – On June 29, 2025, Kuwait issued Ministerial Resolution No. 55 of 2025 to provide for the Executive Regulations for the QDMTT.

June 30, 2025: USA – On June 28, 2025, the G7 announced agreement on a ‘side-by-side’ system to exempt U.S. parented groups from the Income Inclusion Rule and Undertaxed Profits Rule. It implies that the QDMTT applies and that non-US parent groups will still be subject to the IIR, including on US subsidiaries.

June 27, 2025: Belgium – On June 24, 2025, Belgium issued the draft XML Schema for the QDMTT return. 

June 26, 2025: Hungary – On June 19, 2025, the 2025 Spring Tax Package was published in the Official Gazette.

June 25, 2025: Isle of Man – On June 19, 2025, the updated version of the Global Minimum Tax (Pillar Two) Order 2024 was published. 

June 20, 2025: Romania – On June 20, 2025, a draft Order was issued to nominate a single designated entity for QDMTT filing and payment purposes, if there are several constituent entities in Romania that are part of the same group.

June 20, 2025: Slovakia – On June 16, 2025, Slovakia issued a draft law to amend its minimum tax act to provide for the June 2024 and January 2025 OECD Administrative Guidance, as well as EU Directive DAC 9 amendments.

June 17, 2025: Norway – On June 16, 2025, Norway’s Ministry of Finance opened a consultation on a Draft Bill to amend its Minimum Tax Law to implement the OECD’s June 2024 and January 2025 Administrative Guidance.

June 12, 2025: Spain – On June 3, 2025, the draft Pillar 2 forms were issued for public consultation. This includes Form 240 (registration), Form 241 (the GIR) and Form 242 (the top-up tax return).

June 11, 2025: Iceland – On June 5, 2025, Iceland opened a consultation on a draft bill to implement an IIR and QDMTT under the OECD Pillar 2 GloBE rules. 

June 10, 2025: Mauritius – In the 2025 Budget speech delivered on June 5, 2025, Mauritius proposed a Domestic minimum top-up tax (DMTT) effective for income derived on or after July 1, 2025.

For all Pillar 2 Developments, see our Pillar Two Developments Tracker.

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