Analysis of the domestic implementation of Pillar 2 globally. Detailed Country Guides, Local Compliance Requirements, PDF Report Builders, Tools, OECD Administrative Guidance and QDMTT Design Tracking and more.
A high-level view of Pillar 2 implementation and key design features across jurisdictions.
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On July 28, 2026, Monaco issued a draft law to to implement a QDMTT for fiscal years beginning on or after 31 December 2026.
On July 23, 2026, Canada released a narrowly targeted amendment to its Global Minimum Tax Act (“GMTA”) that would broaden the circumstances in which an intra-group financing or investment arrangement must be neutralised when applying the transitional Country-by-Country Reporting (“CbCR”) safe harbour.
Luxembourg has published draft legislation that would implement the OECD’s January 2026 Side-by-Side package, introduce the permanent Simplified ETR Safe Harbour and extend the Transitional CbCR Safe Harbour.
Bill No. 8795 was deposited in the Luxembourg Chamber of Deputies on July 17. 2026. It would amend the Law of 22 December 2023 on minimum effective taxation, which implemented the EU Pillar Two Directive and introduced Luxembourg’s income inclusion rule, undertaxed profits rule and QDMTT.
On July 16, 2026 Barbados issued a guidance note: ‘Qualified Domestic Minimum Top-up Tax (QDMTT): Transitional Rule for Fiscal Year 2024 – Transitional Application of Section 5(4) of the Corporation Top-Up Tax Act, 2024-16‘. This provides guidance on the application of its Conditional QDMTT where some Barbados constituent entities are held through a parent applying an income inclusion rule (IIR), while other Barbados entities in the same multinational group are not exposed to an IIR or UTPR.
On July 13, 2026, the UK government published draft Finance Bill 2026–27 legislation implementing the OECD’s January 2026 Side-by-Side package. The proposals introduce the permanent Simplified ETR Safe Harbour, extend the Transitional CbCR Safe Harbour, provide special treatment for qualifying substance-based tax incentives and implement both the Side-by-Side and Ultimate Parent Entity Safe Harbours.
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On 30 July 2026, the Portuguese Government published Portaria No. 318/2026/1, approving Model 64 – the Pillar Two Top-up Tax Return – and its accompanying
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Monaco for accounting periods beginning on or after December 31, 2026.
Monaco has published draft legislation introducing a Qualified Domestic Minimum Top-up Tax (QDMTT) for multinational enterprise groups. The measure is contained in Bill No. 1129
On July 23, 2026, Canada has released a proposed targeted amendment to its Global Minimum Tax Act that would broaden the circumstances in which an
On July 17, 2026, Bill No. 8795 was deposited in the Luxembourg Chamber of Deputies. This would implement the OECD’s January 2026 Side-by-Side package, introduce
On July 16, 2026 Barbados issued a guidance note: Qualified Domestic Minimum Top-up Tax (QDMTT): Transitional Rule for Fiscal Year 2024 – Transitional Application of
On July 13, 2026, the UK government published draft Finance Bill 2026–27 legislation implementing the OECD’s January 2026 Side-by-Side package.
On July 1, 2026, Australia issued the Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2026 Measures No. 2) Rules 2026. This incorporates elements of the
On June 26, 2026, Cyprus issued Decree 272/2026 to confirm entry-into-force dates for the main January 2026 OECD safe harbour package
On June 22, 2026, the UAE issued Ministerial Decision No. 96 of 2026 to implement the OECD Side-by-Side Tax Package.
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