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

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 GIR XSD

GIR XSD Data Toolkit

Work with GIR XSD data inputs and structured outputs to support Pillar 2 reporting workflows.

Latest Pillar 2 Developments

On May 6, 2026, Switzerland opened a consultation on amendments to the Swiss Minimum Taxation Ordinance (MindStV). The consultation is a response to two parliamentary motions requiring the Federal Council to delay the Swiss application of the OECD January 2025 Administrative Guidance on Article 9.1 of the GloBE Model Rules for one year, so that the guidance applies only to fiscal years beginning on or after January 1, 2025. 

On May 6, 2026, FURS announced the opening of the test submission platform for filing the IIR/UTPR return and the QDMTT return. Both forms are expected to be available on the production eDavki portal in the week 11 May to 15 May 2026.

On May 1, 2026, Australia issued the draft Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2026 Measures No. 2) Rules 2026 for consultation. This includes a one-year extension to the Transitional CbCR safe-harbour and a number of technical amendments to Australia’s Pillar Two rules.

On April 30, 2026, the OECD released its Global Minimum Tax Implementation Toolkit. This is an aid for tax administrations and policy officials and is not a new layer of Pillar Two Administrative Guidance. It doesn’t amend the GloBE Model Rules, introduce new safe harbours, or add new legal filing obligations for MNE groups by itself. However, it does gives MNE groups and advisers useful signals about registration, GIR filing, local GMT returns, payments, penalties, exchange of information, and the practical operation of QDMTTs.

The Netherlands has announced the opening of its Pillar Two filing from June 2026. The BIA/GIR is filed through Digipoort (the government digital gateway). The notification is an online form in the Gegevensportaal (Data Portal), opening on 2 June 2026. The Dutch top-up tax return is filed through Mijn Belastingdienst Zakelijk (My Tax Administration for Businesses), which the main Belastingdienst site says will be available from 1 June 2026.

On April 17, 2026 Brazil opened a public consultation to amend RFB Normative Instruction No. 2,228/2024, which implements Brazil’s domestic minimum top-up tax through the Additional CSLL (QDMTT). Brazil is seeking to align its domestic rules with the OECD January 2026 Administrative Guidance, specifically the new Substance-based Tax Incentive Safe Harbour.

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

Latest Articles

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  • Featured Articles

    Norway Flag

    Norway Pillar Two Filing Guide

    A guide to Norway’s three compliance workstreams for Pillar Two (suppleringsskatteloven): the GloBE Information Return (GIR), the foreign-filer notification, and the Norwegian top-up tax return.

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