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Pillar Two Research Hub: Guidance, Forms, Legislation, Tools and Analysis

Analysis of the domestic implementation of Pillar 2 globally. Detailed Country Guides, Local Compliance Requirements, PDF Report Builders, Tools, OECD Administrative Guidance and QDMTT Design Tracking and more.

Dashboard Global view

Pillar 2 Dashboard

A high-level view of Pillar 2 implementation and key design features across jurisdictions.

Compliance Filing focus

Pillar 2 Compliance Dashboard

Track local filing requirements, timelines, and practical compliance checkpoints by jurisdiction.

Tools CbCR Safe Harbour

Transitional CbCR Safe Harbour Engine

Assess Transitional CbCR Safe Harbour eligibility by tested jurisdiction and export structured outputs.

Tools Filing

Pillar Two Workflow

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..

Latest Pillar 2 Developments

Luxembourg has published draft legislation that would implement the OECD’s January 2026 Side-by-Side package, introduce the permanent Simplified ETR Safe Harbour and extend the Transitional CbCR Safe Harbour.

Bill No. 8795 was deposited in the Luxembourg Chamber of Deputies on July 17. 2026. It would amend the Law of 22 December 2023 on minimum effective taxation, which implemented the EU Pillar Two Directive and introduced Luxembourg’s income inclusion rule, undertaxed profits rule and QDMTT.

On July 16, 2026 Barbados issued a guidance note: Qualified Domestic Minimum Top-up Tax (QDMTT): Transitional Rule for Fiscal Year 2024 – Transitional Application of Section 5(4) of the Corporation Top-Up Tax Act, 2024-16‘. This provides guidance on the application of its Conditional QDMTT  where some Barbados constituent entities are held through a parent applying an income inclusion rule (IIR), while other Barbados entities in the same multinational group are not exposed to an IIR or UTPR.

On July 13, 2026, the UK government published draft Finance Bill 2026–27 legislation implementing the OECD’s January 2026 Side-by-Side package. The proposals introduce the permanent Simplified ETR Safe Harbour, extend the Transitional CbCR Safe Harbour, provide special treatment for qualifying substance-based tax incentives and implement both the Side-by-Side and Ultimate Parent Entity Safe Harbours.

On July 1, 2026, Australia issued the Taxation (Multinational – Global and Domestic Minimum Tax) Amendment (2026 Measures No. 2) Rules 2026 to amend the Taxation (Multinational – Global and Domestic Minimum Tax) Rules 2024.  The amendments incorporate elements of the OECD Agreed Administrative Guidance issued in December 2023, June 2024 and January 2026.

On July 8, 2026, the Ministry of Economy and Finance extended the deadline for filing the GIR, GloBE tax return and payment of top-up tax to September 1, 2026 (from June 30, 2026).

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