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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 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

The Slovak Government has approved draft legislation that would make significant changes to Slovakia’s qualified domestic minimum top-up tax regime. The proposals would implement the OECD’s new Substance-Based Tax Incentives Safe Harbour, extend the Transitional CbCR Safe Harbour and introduce rules preserving Pillar Two filing and payment obligations where a Slovak taxpayer ceases to exist without a legal successor.

The Government approved the bill on 19 August 2026 through Resolution No. 320/2026.

Cyprus has opened a public consultation on amendments to its Pillar Two legislation intended to address observations from the European Commission and align the domestic rules more closely with OECD guidance. The consultation opened on 30 July 2026 and is scheduled to close on 5 September 2026.

On August 7, 2026, Germany published a regulation that gives domestic legal effect to a jurisdiction-by-jurisdiction list of qualifying Pillar Two jurisdictions.

On 14 August 2026, the Swedish Government published a referral to the Council on Legislation proposing extensive amendments to Sweden’s Minimum Top-up Tax Act, Law (2023:875). The referral covers four of the five safe-harbour measures agreed by the OECD/G20 Inclusive Framework in January 2026, as well as changes arising from earlier OECD Administrative Guidance and the May 2026 guidance for 52- and 53-week fiscal years.

The Income Tax (Qualified Domestic Minimum Top-up Tax) Regulations 2026 were made on 28 July 2026, published in the Government Gazette on 8 August 2026 and are deemed to have been in operation from 1 July 2025.

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