Research domestic rules, compare local compliance obligations and build reports with links to the underlying law. Independent analysis for lawyers, accountants and in-house tax teams.
Explore the public guide overview, compliance resources and report walkthrough. These show the structure of the research and the outputs available through membership.
A country guide connects domestic implementation to the underlying legislation.
Public overview and contents; detailed analysis requires membership.
Start from the compliance dashboard to find local filing resources and registration requirements.
Public resource overview; access to individual resources depends on your plan.
The Report Builder lets you select jurisdictions and analysis topics to create a comparative PDF with domestic-law citations.
Public demonstration; report generation is included in Core + Tools.
Choose research or research plus tools. Core: £295 per user/year. Core + Tools: £395 per user/year. Annual billing; VAT, where applicable, is shown at checkout. Compare the plans · Ask about access for your team
A high-level view of Pillar 2 implementation and key design features across jurisdictions.
Track local filing requirements, timelines, and practical compliance checkpoints by jurisdiction.
Generate stakeholder-ready PDF reports and structured Pillar 2 outputs for client delivery.
Assess Transitional CbCR Safe Harbour eligibility by tested jurisdiction and export structured outputs.
Helps tax teams generate workplans, manage GIR filing routes, track local returns and notifications, apply QDMTT jurisdiction-specific tailoring, assess safe harbours, collect evidence and control review/sign-off.
Automated tax engine to calculate whether the Simplified ETR Safe Harbour applies.
Poland’s Parliament completed passage of Sejm Print 3293 on 6 November. Article 2 of the final parliamentary text would apply a 22% ordinary corporate income-tax rate where a taxpayer either exceeded EUR 50 million of Polish revenue or was a constituent entity of a group within Poland’s Top-up Tax Act in the preceding tax year. The bill awaits presidential action and does not amend Poland’s IIR, UTPR or QDMTT rules. Read our analysis.
Belgium’s law of 25 October 2026 was published and entered into force on 30 October. It transposes DAC9, enacts the 15-month QDMTT return deadline and 18-month transition rule, prescribes separate IIR and UTPR returns, and introduces differentiated penalties. It does not by itself activate non-EU GIR exchange under the separate MCAA. Read our updated analysis.
Revenue eBrief No. 164/26 and updated TDM Part 04A-10-02, published on 5 November, explain correction and deletion of accepted Top-up Tax Information Returns using GIR102 and CorrDocRefID, the delete-and-new-initial route for missing or new elements, and RecJurCode mapping for central exchange. The update does not change the existing 15-month and 18-month filing deadlines. Read our analysis.
Finance Bill 173, Schedule 7 paragraph 31, would permit an irrevocable early-application election for specified technical Pillar Two amendments, subject to notice and consent conditions. Separate fixed commencement rules apply to other amendments. These are proposals, not enacted law. Our existing UK analysis now explains the proposed timing rules and qualifications.
Finance Bill 173 as introduced was published on 4 November 2026. Clause 35 and Schedule 7 paragraphs 9–11 carry forward the OECD-list default for Side-by-Side recognition and propose a corresponding change for the narrower UPE Safe Harbour. This advances the July draft and the separate Resolution 39 stage; it is not Royal Assent or a DTT exemption. Our existing UK analysis and country guide have been updated.
Featured Articles
Liechtenstein’s Parliament passed amendments replacing the time-limited Article 28 safe-harbour power and adding Government competence for the GIR MCAA list. The measure awaits the referendum
Poland’s Parliament has passed a bill that would raise ordinary corporate income tax to 22% for taxpayers that were in scope of Poland’s Pillar Two
Ireland Revenue eBrief No. 164/26 adds operational rules for correcting and deleting accepted Top-up Tax Information Returns and for coding the jurisdictions entitled to receive
AADE Decisions A.1236 and A.1237, published on 2 November 2026, prescribe separate domestic top-up tax and IIR/UTPR self-assessment returns. The decisions address designated filers, nil
Royal Decree 101/2026, published in Gazette 1672 on 1 November 2026, rewrites Oman’s Pillar Two registration, filing and payment provisions. Specified amendments apply from the
Curaçao’s final minimum-tax ordinance introduces an IIR from fiscal years beginning in 2025, reserves domestic-tax and UTPR chapters, and sets separate GIR and tax-return deadlines.
Italy’s Revenue Agency rejects using lower 2023 comparatives restated under OIC 34 for the 2024 Pillar Two scope test. We examine Response No. 188/2026 and
Uruguay’s signed IMCD decree dated 16 October 2026 adds previously missing GloBE elections and develops the rules for income, covered taxes, foreign-tax allocation, negative tax
Switzerland adopts a one-year delay to the OECD Article 9.1 DTA guidance for 2024, with foreign IIR and grace-period cap implications.
The OECD’s October 2026 GIR XML guide incorporates the revised reporting framework and sets a June 2028 transition for exchanges, including corrections to earlier returns.
This website is not affiliated with or related to the OECD. We provide independent insights and analysis on the OECD Two-Pillar Solution
© 2026 OECDPillars.com
All Rights Reserved