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On January 13, 2026, Turkey announced an extension in the filing and payment date for the QDMTT return for the 2024 tax period from January 15, 2026 to January 28, 2026.
On January 12, 2026, the EU Commission issued Commission Notice C/2026/253. This provides that for the purposes of Article 32 of the EU Minimum Tax Directive (which provides for the application of international safe harbours), the safe harbours outlined in the OECD Side-by-Side agreement are ‘qualifying international agreements on safe harbours’. This applies to the:
-Simplified ETR Safe Harbour;
-Extension of the Transitional CbCR Safe Harbour;
-Substance-based Tax Incentive Safe Harbour;
-Side-by-Side System (the Side-by-Side Safe Harbour and the UPE Safe Harbour).
On December 29, 2025, Uruguay’s President issued Decree No. 325/025, to provide for exemptions from the QDMTT for entities covered by a tax stability agreement. Note that Law N° 20446 to enact the QDMTT was published in the Official Gazette on January 8, 2026.
On December 31, 2025, Croatia published the Ordinance on automatic exchange of information in the field of taxation in the Official Gazette. This implements DAC9 and also provides the Croatian GIR.
On January 7, 2026, Turkey opened its QDMTT Return filing portal.
Our OECD Pillar Two Tracker covers the latest developments at the OECD, EU and in domestic jurisdictions to keep you up-to-date with the implementation of Pillar Two.
Updated daily and with links to our more detailed analysis on the approach and impact of domestic implementation:
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On December 29, 2025, Uruguay’s President issued Decree No. 325/025, to provide for exemptions from the QDMTT for entities covered by a tax stability agreement.
On December 23, 2025, Korea enacted Law number 21215 to implement the 2026 Tax Reform. This includes a QDMTT from January 1, 2026.
On January 5, 2026, the OECD Released Guidance on amendments to the Pillar 2 rules for the Side-by-Side Tax Package. This includes a new Simplified
On January 5, 2026, the OECD Released Guidance on amendments to the Pillar 2 rules for the Side-by-Side Tax Package. This includes a new Substance-based
On January 5, 2026, the OECD Released Guidance on amendments to the Pillar 2 rules for the Side-by-Side Tax Package. This article looks at a
On January 5, 2026, the OECD Released Guidance on amendments to the Pillar 2 rules for the Side-by-Side Tax Package.
On December 23, 2025, Germany enacted a law to amend the Minimum Tax Act. This follows the two previous discussion drafts and now includes the
On December 23, 2025, Austria published the Tax Amendment Act 2025 in its Official Gazette. This includes amendments to aspects of the December 2023, June
Part III of the Dutch Year-End Decree 2025 (published in the Official Gazette on December 23, 2025) amends the Minimum Tax Executive Decree 2024 for
On December 30, 2025, IRAS issued further details on the Pillar 2 registration process. The registration portal is to be open from May 2026, however,
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