Vietnam has issued a Draft Decree to provide that the QDMTT will be deemed to be zero for enterprises implementing power plant projects under the Build-Operate-Transfer (BOT) mechanism provided that the contract has a tax commitment and is signed before the effective date of Resolution 107/2023/QH15 (January 1, 2024).

Order No. 158/2025 XXV issued on December 12, 2025 provides that for constituent entities whose fiscal year ended between December 31, 2024 and March 31, 2025 the filing deadline for Form 62 (the Pillar 2 Registration Form) is the last day of the 15th month following the end of that fiscal year.

On December 17, 2025, Australia issued updated guidance on the application of Pillar 2 including the treatment of consolidated groups, misaligned fiscal years and prior period adjustments.

On December 16, 2025, the Dutch Parliament passed a law to amend the Minimum Tax Act for the June 2024 and January 2025 OECD Administrative Guidance.

The Law to exchange information under the OECD GIR MCAA was published in the Official Gazette on December 16, 2025.

On December 9, 2025, France released its GIR (based on the OECD template) and updated its User Guide.

On December 11, San Marino deposited its instrument of ratification for the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (the STTR Convention).

On December 4, 2025, the Thai Revenue Department issued Notification No’s 4 and 5 on the determination of employees and tangible assets for the purpose of the Substance-Based Income Exclusion.

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