Pillar Two Tools & Analysis

Domestic Pillar Two Implementation

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Latest Pillar 2 Developments

August 6, 2025: South Korea – Koreas 2025 Tax Reform Proposal (announced on July 31, 2025), provides that a QDMTT will be applied from January 1, 2026.

August 4, 2025: OECD – On 30 July 2025, the OECD released a GloBE Information Return (GIR) Status Message XML Schema for Pillar Two.

August 4, 2025: Luxembourg – On July 24, 2025, the Luxembourg Government issued:

 – a draft law to amend its Minimum Tax Law to provide for the January 2025 OECD Administrative Guidance and the EU DAC 9 GIR filing requirements: and

 – a draft Regulation which includes the format of the GIR

July 31, 2025: Kuwait – On July 16, 2025, Kuwait updated its electronic registration portal to include Pillar 2 registration.

July 28, 2025 – On July 24, 2025, the UK issued a notice to amend the Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025 (SI 2025/406) to include Spain and Guernsey as jurisdictions qualifying for GloBE purposes (QIIR, QDMTT and the QDMTT Safe Harbour).

July 24, 2025: UK – On July 21, 2025, the UK issued draft legislation for the January 2025 OECD Administrative Guidance and other relevant changes. 

July 16, 2025: Australia – On July 16, 2025, the ATO released a Draft Practical Compliance Guideline on the transitional approach to filing obligations for the IIR,UTPR and QDMTT.

July 11, 2025: Romania – On July 9, 2025, ANAF Order 1.729/2025 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.

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

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