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Global Pillar 2 coverage Fully cited to domestic law Built for tax professionals

Find the Pillar Two rules and filing requirements that apply to your group.

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.

Analysis by Lee Hadnum — Chartered Accountant and former Senior Tax Analyst at Bloomberg Tax, with 20 years of experience in international tax planning.

See what you can use before you join

Explore the public guide overview, compliance resources and report walkthrough. These show the structure of the research and the outputs available through membership.

Research a jurisdiction

A country guide connects domestic implementation to the underlying legislation.

  • Overview and source links
  • Differences from the Model Rules
  • QDMTT, filing and penalty analysis
View a country guide overview →

Public overview and contents; detailed analysis requires membership.

Compare compliance obligations

Start from the compliance dashboard to find local filing resources and registration requirements.

  • Domestic returns and forms
  • Registration requirements
  • Country guides and compliance calendar
Explore the compliance dashboard →

Public resource overview; access to individual resources depends on your plan.

Build a sourced PDF report

The Report Builder lets you select jurisdictions and analysis topics to create a comparative PDF with domestic-law citations.

  • Select the countries you need
  • Choose topics such as safe harbours and elections
  • Export the report for your working papers
View the report walkthrough →

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

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

SARS’s Payment Rules guide (revision 39, effective 16 October 2026) adds dedicated Investec Bank instructions for Global Minimum Tax payments from overseas. Section 3.5(d) requires the SWIFT route through Investec and the prescribed Payment Reference Number (PRN); the separate FNB foreign-payment table expressly excludes GMT. The route is restricted to non-domestic foreign taxpayers without another available payment channel. A foreign taxpayer with a South African bank account may not use SWIFT. Payments must be in rand, with the correct 19-digit PRN, and bank charges must not reduce the amount due to SARS. This is an administrative payment-channel update under the existing GMT framework. SARS announcement, 16 October; Official guide, sections 3.5 and 4.

CRA technical interpretation 2025-1079701E5, dated 19 October 2026, distinguishes provincial Crown corporations’ tax returns from GIR filing. Where section 125 constitutional immunity removes liability under Parts 2 and 3 of the Global Minimum Tax Act, CRA considers that the section 61(1)–(2) tax returns are generally not required. Subsidiaries benefit only to the extent their own immunity applies. Immunity does not itself remove any GIR obligation arising under section 60(1); that obligation must be assessed separately. Section 4 expressly binds the Crown. The letter gives general comments, not a taxpayer-specific determination of immunity or a new statutory exemption. CRA letter — reproduced original text; Official Act, sections 4, 60 and 61; Constitution Act, 1867, section 125.

Uruguay’s Presidency has published signed IMCD regulations dated 16 October 2026. Articles 27–32 specify the Transitional CbCR Safe Harbour, covering fiscal years beginning on or before 31 December 2027 and ending no later than 30 June 2029. Article 37 assigns the designated local filer responsibility for the return and group payment. The existing 15-month filing period remains; an extension to 18 months for a first transition year requires DGI action. The Presidency copy is listed as Decree S/N/026; a numbered Gazette version and publication date have not been independently verified. Official decree; Read our analysis.

Law No. 2026-963 of 19 October 2026, published in the Official Journal on 20 October, authorises approval of the Multilateral Competent Authority Agreement on the Exchange of GloBE Information, signed by France on 9 July 2025. Parliament definitively adopted the sole authorising article on 7 October. This completes the legislative authorisation stage; it does not by itself establish an active bilateral exchange relationship. Agreement section 8(1)–(2) requires matching notifications from the sending and receiving authorities. Groups should distinguish this authorisation from activation of the relevant exchange relationship. Official promulgation record; Definitive text, sole article; Agreement, section 8.

NAV released form 25GLBADO in ONYA for 2025 top-up taxes and the QDMTT advance, with completion guidance and field definitions. Filing is electronic through ONYA.

For calendar-year FY2025, the advance return and payment are due on 20 November 2026. The annual return and payment are normally due on 31 March 2027, or 30 June 2027 where 2025 is the taxpayer’s transition year. Official NAV announcement; Form and completion guides.

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