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

The Isle of Man Treasury has made the Global Minimum Tax (Pillar Two) (Amendment) Order 2026, SD 2026/0127, dated 18 June 2026. It comes into operation on the day after Tynwald approval.

The Order embeds the OECD Central Record for Purposes of the Global Minimum Tax as an updated source of Administrative Guidance, it adds the OECD’s 2026 Side-by-Side Package to the domestic interpretive framework, and it expands the Treasury’s recognition power so that the Isle of Man can recognise another jurisdiction as having a Qualified Side-by-Side Regime or Qualified Ultimate Parent Entity Regime.

On June 19, 2026, Brazil issued IN RFB No. 2,329/2026. This clarifies how a multinational group can centralise payment of Brazil’s Additional CSLL in one Brazilian constituent entity, and addresses a timing issue under Brazil’s RSGT regime, where the fiscal year of the Brazilian jurisdiction does not align with the fiscal year covered by the group’s Country-by-Country Report (which can impact on the Transitional CbCR Safe Harbour).

On June 16, 2026, the Dutch Ministry of Finance opened an internet consultation on the Draft Safe Harbours Bill. The consultation closes on July 14, 2026 and includes draft legislation to implement the OECD Side-by-Side package into the domestic law.

On June 15, 2026, the 2025 final QDMTT return and the final IIR return for 2024 and 2025 was published in the Official Gazette.

On June 12, 2026, the Belgian tax authorities announced an extension of the filing deadline for the GIR notification form (for FY2024), moving it from June 30, 2026 to September 30, 2026. The official filing portal is expected to become available as from July 1, 2026.

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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