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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.

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
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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
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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
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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

Indonesia’s Directorate General of Taxes announced that it signed the GIR-MCAA declaration during the 27–29 October 2026 Competent Authorities Conference in Kotor, Montenegro. The authority says automatic GIR exchanges for Indonesia are scheduled to begin in 2027.

This advances the exchange framework but does not establish that any particular bilateral exchange relationship is active. Existing PER-6/PJ/2026, Articles 12(5)–(6), 14–15 and 31, retain the qualifying competent authority agreement and notification conditions relevant to foreign GIR filing. The announcement is not a domestic return or payment deadline extension. Official signing announcement; existing administrative rules.

Sweden submitted Proposition 2026/27:9 on 27 October 2026, advancing the 3 September Council on Legislation referral. It remains a government proposal, not an enacted change.

Proposed Chapter 6, section 2 a would move liability for the full domestic top-up tax allocated to a Swedish-resident joint venture or its Swedish-resident subsidiary from Swedish group constituent entities to the joint venture or subsidiary itself. Related procedural amendments would require its own domestic top-up tax return. The Government aims to address the joint-venture-specific QDMTT Safe Harbour switch-off; the bill is not a new OECD qualification decision.

Proposed commencement is 1 March 2027, normally for fiscal years beginning after 28 February 2027. Earlier application for years beginning after 31 December 2023 would require the joint venture, its subsidiaries and the constituent entities in the relevant group all to elect; it is not automatic retrospective relief. These central measures were already in the September referral. Official bill, sections 2.1–2.2, 4 and 7, and Annex 5.

On 29 October 2026, FPS Finance announced that tax returns due around 31 October 2026 may be filed by 16 November 2026 following the cyberattack affecting MyMinfin and other services. For Pillar Two, the relevant comparison is with affected end-October tax-return deadlines, including the QDMTT and IIR return timetable previously extended to 31 October. This is temporary administrative filing relief, separate from the pending statutory QDMTT deadline amendment. The published general notice does not separately enumerate Pillar Two notifications; it should not be read as extending tax payment dates or reopening an already expired GIR deadline. Official FPS Finance update, 29 October 2026.

At Budget 2026 on 28 October, the UK Government confirmed that Finance Bill 2026–27 will implement the OECD Side-by-Side package and make further amendments to Multinational Top-up Tax and Domestic Top-up Tax. The package was announced on 13 July 2026. This is confirmation of the planned legislation, not enactment or a newly announced safe harbour.

Official Budget statement, OOTLAR paragraph 1.40; updated HMRC impact note. Our July draft analysis, with a dated Budget update.

Austria’s draft Tax Amendment Act 2026 (148/ME), received by Parliament on 22 October, remains in consultation until 3 November 2026. Article 3, items 18 and 20, would move the minimum-tax preliminary return and payment deadline from 31 December to 15 December of the second calendar year following the preliminary-return period, applying first to periods from 2026.

The explanatory notes expressly identify 15 December 2028 for the 2026 period; the 2024 and 2025 periods would retain 31 December of the respective second following year. This is a proposal, not an enacted deadline change. Draft Article 3, items 18 and 20; explanatory notes, item 18; official consultation record.

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