Pillar Two Tools & Analysis

Domestic Pillar Two Implementation

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Latest Pillar 2 Developments

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.

June 6, 2025: Denmark – On June 3, 2025, Bill 2024/1 LSV 194 A to amend the Danish Minimum Tax Act for the June 2024 and January 2025 OECD Administrative Guidance was passed by Parliament. 

June 6, 2025: Hong Kong – The Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025 has been published in the Official Gazette. The law is now enacted. 

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

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