Pillar Two Research Hub: Guidance, Forms, Legislation, Tools and Analysis

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.

In May 2026, the Swedish Tax Agency (Skatteverket) updated its public guidance on Sweden’s implementation of the Pillar Two global minimum tax regime under the Additional Tax Act. Skatteverket confirms how Swedish constituent entities should approach the first wave of GloBE Information Return filing, central filing, automatic exchange and local Swedish compliance where exchange relationships may not yet be fully activated by the filing deadline.

On May 18, 2026, the UK updated its statutory Pillar Two guidance, Notice 2 — Pillar Two top-up taxes relevant territories and taxes, expanding and amending the UK-recognised lists of jurisdictions and taxes relevant to the operation of the UK’s Multinational Top-up Tax (MTT) and Domestic Top-up Tax (DTT) regimes. The update generally ties into the OECD Central Record, however, it appears to contain an anomaly in relation to Qatar. Section 1.2 lists Qatar’s QDMTT as qualifying from 1 January 2024, whereas Qatar’s domestic materials, the OECD Central Record, HMRC’s own reference list and Notice 2’s accredited-QDMTT table all point to 1 January 2025.

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