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

Order No. 76/2026-XXV of June 3, 2026, allows constituent entities whose fiscal year ended between 31 December 2024 and 31 March 2025 to submit the Article 46(1) declarations – including the Article 45(1)(b) top-up tax information return/GIR-equivalent return and the Article 45(1)(c) tax assessment return – without additions or penalties until 30 September 2026. The registration declaration under Article 45(1)(a) is not covered.

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

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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