On December 4, 2025, the Thai Revenue Department issued Notification No’s 4 and 5 on the determination of employees and tangible assets for the purpose of the Substance-Based Income Exclusion.

On December 10, 2025, Sweden gazetted amendments to its Global Minimum Tax Act to implement the OECDs June 2024 Administrative Guidance.

On December 4, 2025, the Slovenian Official Gazette published Law No. 3396, amending the Tax Procedure Act. Articles 29 and 40 of the amendment law include provisions to introduce the Pillar 2 EU information exchange provisions in DAC 9.

On November 25, 2025, the Finnish Tax Administration published guidance on the allocation of profits/losses and taxes between group entities to take account of the June 2024 OECD Administrative Guidance.

On 18 November 2025, Thailand’s Ministry of Finance issued notification no. 1 under the Minimum Tax Law to provide for the Transitional SBIE rates.

On December 3, 2025, France updated its Pillar 2 Guidance to include guidance on:

 -the procedures for taking into account deferred taxes and assets transferred in respect of the transition year and subsequent years;

– the temporary exemption for groups in their initial phase of international activity.

On November 26, 2025, the ATO updated its Pillar Two website guidance to include:

-a sample combined global and domestic minimum tax return for a Group Entity;

-a sample combined global and domestic minimum tax return for a designated local entity (DLE).

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