Pillar Two Tools & Analysis

Domestic Pillar Two Implementation

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Latest Pillar 2 Developments

July 16, 2025: Australia – On July 16, 2025, the ATO released a Draft Practical Compliance Guideline on the transitional approach to filing obligations for the IIR,UTPR and QDMTT.

July 11, 2025: Romania – On July 9, 2025, ANAF Order 1.729/2025 was issued to nominate a single designated entity for QDMTT filing and payment purposes, if there are several constituent entities in Romania that are part of the same group.

July 9, 2025: Bahrain – On July 2, 2025, Bahrain issued its Advance Payments Manual for details on the procedures for estimating and remitting advance DMTT liabilities.

July 8, 2025: Japan – On June 30, 2025, Japan issued its updated GIR to reflect the OECD GIR changes in January 2025.

June 30, 2025: Kuwait – On June 29, 2025, Kuwait issued Ministerial Resolution No. 55 of 2025 to provide for the Executive Regulations for the QDMTT.

June 30, 2025: USA – On June 28, 2025, the G7 announced agreement on a ‘side-by-side’ system to exempt U.S. parented groups from the Income Inclusion Rule and Undertaxed Profits Rule. It implies that the QDMTT applies and that non-US parent groups will still be subject to the IIR, including on US subsidiaries.

For all Pillar 2 Developments, see our Pillar Two Developments Tracker.

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