Pillar Two Tools & Analysis

Domestic Pillar Two Implementation

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Latest Pillar 2 Developments

November 6, 2025: Mauritius – A Communique of October 29, 2025 issued by the MRA provides that:

– The QDMTT applies to a resident company forming part of an in-scope multinational enterprise group with a fiscal year ending on or after January 1, 2025;

– The deadlines for QDMTT notifications that are already due, have been extended to 30 November 2025;

– The online portal for making a QDMTT notification is now open.

November 4, 2025: Kenya – On November 3, 2025, Kenya issued the Draft Income Tax (Minimum Top Up Tax) Regulations, 2025 to provide for the detailed application of the Pillar 2 DMTT.

November 4, 2025: Italy – On 30 October 2025, the Finance Department of the Ministry of Economy and Finance published Guidance on the submission of the GIR. This follows the Decree of October 16, 2025 that included the format of the GIR and DAC 9 implementation.

November 3, 2025: Ireland – On October 16, 2025, Ireland published its 2025 Finance Bill. This includes amendments for the January 2025 OECD Administrative Guidance, DAC 9 implementation as well as other technical amendments:

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.

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

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