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

Germany’s Act approving the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (BGBl. 2026 II No. 220), dated 30 September, was promulgated on 5 October 2026 and entered into force on 6 October. Article 1 approves the agreement; Article 2(2) provides that the agreement’s own entry into force for Germany under section 8(2) will be announced separately. The Act therefore completes domestic legislative approval but does not by itself activate exchange relationships. Under section 3, first-year exchanges are due within six months after the filing deadline and subsequent exchanges within three months, subject to the reciprocal notifications required by section 8. Official Gazette; Act and agreement text.

Romania deposited its instrument of ratification of the STTR Multilateral Convention on 2 October 2026. The OECD records entry into force for Romania on 1 February 2027. Its deposited position lists 23 tax agreements and elects Article 12(5), which makes entry into effect dependent on notifications confirming completion of internal procedures for the relevant agreement. The February entry-into-force date is therefore not a general STTR tax commencement date; treaty coverage and effective fiscal years require bilateral checks. Official depositary status; Romania’s deposited position, Articles 2 and 12.

Singapore’s Parliament passed the Finance (Income Taxes) Bill 2026 (Bill 22/2026) on 6 October. The Bill would amend the Multinational Enterprise (Minimum Tax) Act 2024 to support the Side-by-Side Safe Harbour, GloBE Information Return exchange and local fallback filing, class-based MTT/DTT return exemptions, and prescribed DTT accounting rules. It still requires presidential assent and publication before becoming law, with several provisions dependent on regulations or ministerial commencement. Official Bill; second-reading speech. Read our detailed analysis.

Thailand’s Revenue Department has opened a consultation, running from 6 October to 5 November 2026, on principles for a Draft Act on Qualified Refundable Tax Credits. The proposed framework covers Revenue Department administration, electronic certificates, tax settlement, cash refunds and transfers; eligibility and credit rates would be prescribed by Royal Decree. This is a consultation on legislative principles, not an enacted credit. Official consultation notice; consultation principles. Read our detailed analysis.

Norway’s 2027 budget proposition proposes separate statutory powers for the Pillar Two safe harbours, with intended application of most Top-up Tax Act amendments to financial years beginning after 31 December 2025. This follows the June consultation and remains a legislative proposal. Official proposition, chapter 7; parliamentary status. Read our detailed analysis.

A Belgian Chamber committee has unanimously approved a bill implementing DAC9 and moving the ordinary statutory QDMTT return deadline from 11 to 15 months after year-end, with an 18-month transitional rule for fiscal years beginning no later than 31 December 2024. The bill would establish the framework for targeted GIR exchange and is not yet enacted. Committee-adopted text; read our detailed analysis.

On 8 October 2026, Cyprus tabled a Pillar Two amendment bill to preserve the existing CyDMTT for 2025 and introduce a separate QDMTT for financial years beginning on or after 31 December 2025 (2026 for calendar-year groups). The proposals align the operative domestic charge with the qualified-tax framework and add accounting, currency and transition rules, alongside reporting changes and corrections. The bill remains subject to parliamentary enactment.

Read our detailed analysis.

The Belgian tax authorities have announced a further extension of several key Pillar Two compliance deadlines:

– QDMTT Return – The filing deadline has been extended to 31 October 2026 for reporting years beginning on or after 31 December 2023 and ending between 1 January 2024 and 31 October 2025.

– IIR Return – The deadline for IIR top-up tax returns that would otherwise become due before 31 October 2026 has been deferred to that date.

–GIR Notification – The deadline for the notification of the GIR filing entity has also been extended to 31 October 2026 for the relevant reporting years covered by the separate announcement.

IN RFB No. 2,342/2026, signed on 15 September 2026 and published on 18 September 2026, amends IN RFB No. 2,228/2024, which regulates Brazil’s Additional Social Contribution on Net Profit (CSLL). The Additional CSLL is Brazil’s qualified domestic minimum top-up tax, introduced by Law No. 15,079/2024.

The principal change is the incorporation of the Substance-Based Tax Incentives Safe Harbour, known in Brazil as the RSGIF. This reflects the OECD’s January 2026 Side-by-Side Package, which allows certain qualifying tax incentives to be treated as an addition to covered taxes, subject to a substance-based cap.

On 15 September 2026, the Dutch government presented a bill that would introduce four new Pillar Two safe harbours, extend the Transitional Country-by-Country Reporting Safe Harbour and amend the treatment of certain 52- and 53-week accounting periods. This forms part of the 2027 Tax Plan, although several provisions would apply retrospectively to fiscal years beginning in late 2025 or in 2026. 

On 11 September 2026, the OECD released a package of guidance and implementation materials that provides for the exclusion of Explicitly Conditional Taxes from Covered Taxes, clarifies the treatment of mismatched fiscal periods under the Qualified Domestic Minimum Top-up Tax Safe Harbour, updates the GloBE Information Return and establishes the detailed framework for full legislative reviews of domestic minimum tax rules.

Uruguay’s presidential decree dated 31 August 2026 replaces the conditional DMTT payment waiver in Decree No. 325/025 with a compensation mechanism. Article 1 requires in-scope constituent entities allocated DMTT in Uruguay to comply with their DMTT obligations and pay the tax; article 7 repeals the earlier decree.