Pillar Two Tools & Analysis

Domestic Pillar Two Implementation

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Latest Pillar 2 Developments

October 30, 2025: South Africa – On October 28, 2025, Government Notice No. 6763 was issued which extended some of the Pillar 2 filing and notification deadlines.

October 29, 2025: Spain – On October 29, 2025, Order HAC/1198/2025, of October 21 was published in the Official Gazette. This approves the final versions of three specific Pillar 2 forms – Form 240 (registration), Form 241 (the GIR) and Form 242 (the top-up tax return).

October 27, 2025: Australia – On October 26, 2025, Australia opened a consultation on changes to the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024 for the OECD’s Administrative Guidance.

October 23, 2025: Slovakia – On October 21, 2025, Slovakia’s Parliament approved a Law to amend its Minimum Tax Act to provide for the June 2024 and January 2025 OECD Administrative Guidance, as well as EU DAC 9 Directive amendments.

October 23, 2025: Italy – Italy issued the Decree of October 16, 2025 which provides for the format of the GIR, the method of submission and exchange (updated for the January 2025 OECD Administrative Guidance) as well as the EU DAC 9 information exchange provisions.

October 23, 2025: Belgium – On October 22, 2025, Belgium issued Circular 2025/C/68 which provides detailed guidance on the application of the Pillar 2 rules in Belgium.

October 22, 2025: Hungary – On 21 October, 2025, Form 24GLBADO for the Advance QDMTT Tax Declaration was published on the ONYA platform and is available for submission.

October 22, 2025: Vietnam – On October 21, 2025, Vietnam released Decision 3563/QD-BTC 2025 on the Administrative Procedures for the Minimum Tax. This includes the final forms to be submitted for notification, registration and returns.

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

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