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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 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

Singapore has opened a consultation on the proposed Finance (Income Taxes) Bill 2026, a package that would amend the Income Tax Act 1947 and the Multinational Enterprise (Minimum Tax) Act 2024 (MMTA).  The Bill contains 22 amendments: 20 amendments to the Income Tax Act and two amendments to the MMTA. The two MMTA changes are to implement the Side-by-Side Safe Harbour under the OECD’s January 2026 package and to implement the GloBE information return exchange framework.

On June 8, 2026, the OECD released the Guidance on the use of the GIR XML Schema for the first GloBE filing and exchange cycle. This provides guidance for the use of the GIR XML Schema for first GloBE filings and exchanges in 2026 including practical fixes, workarounds and the switch-off of certain validation rules.

In June 2026, The Bahamas issued the Domestic Minimum Top-Up Tax (Amendment) Bill, 2026 to provide for various administrative amendments to its DMTT regime. If enacted the law would come into force on July 1, 2026. 

On June 4, 2026, the Norwegian Ministry of Finance published draft legislation implementing the OECD January 2026 Side-by-Side Package. The draft legislation includes:

– Side-by-Side Safe Harbour
– UPE Safe Harbour
– Substance-based Tax Incentive Safe Harbour
– Simplified ETR Safe Harbour
– Extension of the Transitional CbCR Safe Harbour

On June 1, 2026, Belgium published the final QDMTT Return for the 2024 assessment year, in the Official Gazette.

On May 29, 2026, the EU Commission published an updated Pillar Two FAQ that states that all EU Member States must treat Cyprus as having a qualified income inclusion rule under the EU Pillar Two Directive. Cyprus is not a member of the OECD/G20 Inclusive Framework, and its IIR did not appear on the OECD Central Record or in the OECD central GIR filing support document, but EU companies still must consider the Cypriot IIR qualified for the first Pillar Two returns due by 30 June 2026.

The Commission states that the qualified status of the Cypriot IIR derives from Article 3(18) of the EU Pillar Two Directive for fiscal years beginning on or after 31 December 2023, so all EU Member States should treat Cyprus as having a qualified IIR in effect. The FAQ also says Cyprus can receive top-up tax information returns as of 31 May 2026 and is obliged under EU law to exchange under DAC9 by the first exchange deadline; if an MNE centrally files in Cyprus, other EU Member States should not require domestic filing at that time in line with DAC9.

 

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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