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Comprehensive analysis of the domestic application of the Pillar Two GloBE rules in 62 jurisdictions.
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Up to date analysis and links to all domestic Pillar Two returns, forms and notifications.
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Jurisdictional breakdown and links to all enacted and draft Pillar Two legislation.
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Analysis of the application of the OECD Model Rules, Commentary and Administrative Guidance.
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Domestic Pillar Two Deep-Dives
A breakdown of jurisdictional approaches to QDMTTs, the Transitional CbCR Safe Harbour and the implementation of the OECD Administrative Guidance.
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Pillar Two Developments Tracker
Up to date analysis of global Pillar Two developments.
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Latest Pillar 2 Developments

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 aspects of the December 2023, June 2024, and January 2025 OECD Administrative Guidance.

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, a draft registration form and explanatory notes have been issued. NB there is also a requirement to disclose companies incorporated or registered in Singapore that had shifted their tax residency from Singapore to a foreign jurisdiction after November 30, 2021.

On December 29, 2025, the Thai Cabinet approved 4 draft laws/regulations on the implementation of the Pillar 2 rules in Thailand. The laws need to be published in the Official Gazette. The laws are:

-Draft Royal Decree on the criteria for considering liability to additional tax for groups of multinational legal entities undergoing corporate restructuring, together with an explanatory note (principles and rationale) and a summary analytical note.

-Draft Royal Decree prescribing legal entities that are not related legal entities, together with an explanatory note (principles and rationale) and a summary analytical note.

-Draft Ministerial Regulation, issued under the Executive Decree on Top-Up Tax, B.E. 2567 (2024), on the allocation of residual additional tax received by Thailand to related legal entities established in Thailand, together with an explanatory note (principles and rationale) and a summary analytical note.

-Draft Ministerial Regulation, issued under the Executive Decree on Top-Up Tax, B.E. 2567 (2024), on adjustments to income, expenses and taxes within scope for the calculation of additional tax, together with an explanatory note (principles and rationale) and a summary analytical note.

On December 23, 2025, Liechtenstein published an amendment to its GloBE Regulation to provide for a list of jurisdictions that apply for GIR information exchange purposes.

On December 23, 2025, Liechtenstein published the Act of  November 7, 2025 amending the GloBE Act to provide for the GIR MCAA and amended registration provisions.

On December 26, 2025, Turkey published the Communique for the detailed application of the IIR. UTPR and QDMTT in its Official Gazette.

On December 19, 2025, the Finnish Official Gazette issued Decision No. 1249/2025, on the GLoBE tax information return filing, including DAC9 implementation.

On December 19, 2025, the Danish Official Gazette published an Executive Order providing for GIR information reporting requirements:

On December 17, 2025, the Danish Official Gazette published Law No. 1643 to amend the Minimum Tax Act for the GIR filing/DAC9, QDMTT Design and changes to payment.

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:

Pillar Two Developments Tracker

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