Find the Pillar Two rules and filing requirements that apply to your group.

On 19 October, Ireland’s Minister for Finance presented Finance (No. 2) Bill 2026 (Bill 98). Section 72 proposes Side-by-Side IIR/UTPR relief, narrower UPE-jurisdiction UTPR relief, substance-based tax incentive relief and a simplified-ETR framework. It would extend the Transitional CbCR Safe Harbour and amend GIR administration and penalties. The proposed changes have provision-specific application dates and remain subject to enactment. Official Bill, section 72; Read our analysis.

The Barbados Revenue Authority published Guidance Note OGC No. 17/2026 on 15 October 2026 (the note is dated 7 October). It confirms submission of Barbados’ initial GIR MCAA notifications and explains that signing alone does not activate bilateral exchange: matching notifications are needed.

For calendar-year FY2024, the note distinguishes the 31 December 2026 exchange deadline from the 30 June 2026 filing deadline. It says no separate Barbados GIR is required where the relationship is activated and the GIR is received by 31 December; otherwise the BRA may notify the group to file locally. This clarifies administration of the existing framework, not a new filing extension or confirmation of any particular activated relationship.

Existing regulation 5(3) requires filing within 30 days of notification where a complete or substantially complete GIR has not been received by the exchange date. Foreign-filing notification obligations remain; foreign filing does not extend payment deadlines (regulations 5(2) and 8(2)). Official guidance and download; S.I. 2026 No. 65, regulations 5 and 8.

In its 9 October 2026 response on Bill 37025, the Dutch Government confirms that the asset-transfer/M&A simplification in proposed Article 8.11d(2)–(4) is optional. It says the choice is an annual election in the GIR; without it, Article 8.11d(1) remains the starting point. The Government declined to amend the wording. The submitted bill’s conditions—unchanged tax bases (apart from goodwill) and corresponding deferred taxes at at least the minimum rate—still govern access. This clarifies how the proposal is intended to operate; it is not enactment or a new safe harbour. Official response, section 4, final answer; Bill, Article 8.11d. Earlier analysis of the bill.

Bermuda’s Tax Credits (Administrative) Regulations 2026 (BR 114/2026), made on 8 October and operative from 9 October, prescribe registration and group claim procedures under the existing Tax Credits Act. Regulation 15 sets the original claim deadline at the end of the tenth month after the fiscal year, subject to the next-business-day rule. The instrument implements existing credit entitlements; it is not a new GIR deadline or an OECD qualification decision. Official regulations; Read our analysis.

Sweden submitted Proposition 2026/27:4 to Parliament on 13 October 2026; it was referred to the Tax Committee on 14 October. This advances the August Council on Legislation referral, but is not parliamentary adoption or enactment.

Proposed Chapter 8, sections 18 a–18 b retain Side-by-Side IIR/UTPR relief and narrower UPE-jurisdiction UTPR relief, subject to an Inclusive Framework-approved regime. The bill also extends the Transitional CbCR Safe Harbour to fiscal years beginning before 1 January 2028 and ending no later than 30 June 2029. Proposed commencement is 1 January 2027, normally for years beginning after 31 December 2026; transitional point 3 permits elective earlier application, with the new Side-by-Side, UPE and qualified-incentive provisions no earlier than years beginning after 31 December 2025. Parliamentary record; Official bill, pages 15–17.