October 3, 2025: Turkey – On October 3, 2025, Turkey published the Draft Communique on the Minimum Tax Law, and the Draft GIR, for consultation. Whilst Turkey has enacted its Minimum Tax Law, a lot of the detailed application of the GloBE rules was left to a further Regulation. This Communique therefore provides for the detailed rules for the implementation of the GloBE rules in Turkey.
October 3, 2025: Croatia – On September 18, 2025, Croatia opened a consultation on a Draft Bill to amend its Minimum Tax Act. The amendments are primarily to amend the QDMTT accounting standard so that the Croatian QDMTT qualifies for the QDMTT Safe Harbour and to provide for the notification deadline for appointing a designated filing entity.
October 2, 2025: OECD – On September 30, 2025, the OECD issued an updated list of signatories to the GIR MCAA to include Germany, Liechtenstein and Norway.
October 1, 2025: Hong Kong – On September 26, 2025, Hong Kong updated its Pillar 2 guidance to include information on its Pillar 2 Portal, applications for Group Codes and mandatory e-filing of profit tax returns for Pillar 2 groups.
September 30, 2025: Germany – On September 29, 2025, the Federal Ministry of Finance opened a consultation on a Draft Regulation for the implementation of the Minimum Tax Act. This provides for compliance rules for the exchange of the GIR and simplified reporting.
September 17, 2025: The Netherlands – On September 16, 2025, The Netherlands Cabinet issued a Draft Bill for the Second Amendment to the Minimum Tax Act to implement the June 2024 and January 2025 OECD Administrative Guidance (as well as the EU DAC 9 proposals).
September 17, 2025: Japan – Japan has launched its Multinational Enterprise Information Reporting Portal for filing Pillar 2 returns. Returns related to global minimum tax for the fiscal year starting from April 1, 2024, are accepted from September 16, 2025.
For all Pillar 2 Developments, see our Pillar Two Developments Tracker.
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On September 18, 2025, Croatia opened a consultation on a Draft Bill to amend its Minimum Tax Act. The amendments are primarily to amend the
On September 26, 2025, Hong Kong updated its Pillar 2 guidance to include information on its Pillar 2 Portal, applications for Group Codes and mandatory
On September 29, 2025, the Federal Ministry of Finance opened a consultation on a Draft Regulation for the implementation of the Minimum Tax Act. This
We keep track of all domestic Pillar Two forms issued to date, including links to domestic forms and notices for each relevant jurisdiction.
On September 16, 2025, The Netherlands Cabinet issued a Draft Bill for the Second Amendment to the Minimum Tax Act to implement the December 2023,
Japan has launched its Multinational Enterprise Information Reporting Portal for filing Pillar 2 returns.
On 6 September 2025, Nigeria’s Tax Act 2025 was published in the Official Gazette. This includes a DMTT (without any of the detailed GloBE adjustments
On September 11, 2025, the Polish Ministry of Finance issued the draft Pillar 2 notifications and top-up tax returns for consultation.
On August 29, 2025, Vietnam issued its Decree for the detailed implementation of the Pillar 2 rules from January 1, 2024.
On September 2, 2025, Portugal issued Ordinance No. 290/2025/1 which includes the format for the Pillar 2 registration form (Form 62).
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