Pillar 2 Developments Tracker
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OpenLatest Developments
On June 19, 2026, Brazil issued IN RFB No. 2,329/2026. This clarifies how a multinational group can centralise payment of Brazil’s Additional CSLL in one Brazilian constituent entity, and addresses a timing issue under Brazil’s RSGT regime, where the fiscal year of the Brazilian jurisdiction does not align with the fiscal year covered by the group’s Country-by-Country Report (which can impact on the Transitional CbCR Safe Harbour).
On June 16, 2026, the Dutch Ministry of Finance opened an internet consultation on the Draft Safe Harbours Bill. The consultation closes on July 14, 2026 and includes draft legislation to implement the OECD Side-by-Side package into the domestic law.
On June 15, 2026, the 2025 final QDMTT return and the final IIR return for 2024 and 2025 was published in the Official Gazette.
On June 12, 2026, the Belgian tax authorities announced an extension of the filing deadline for the GIR notification form (for FY2024), moving it from June 30, 2026 to September 30, 2026. The official filing portal is expected to become available as from July 1, 2026.
On June 10, 2026, the EU issued the ‘Manual for MNE Groups on Global Minimum Tax (Pillar Two) Compliance Obligations‘. This provides country level analysis of Pillar Two filings in Austria, Belgium, Croatia, Cyprus, Czech Republic, Finland, France, Germany, Greece, Ireland, Poland, Romania, Slovenia and Sweden.
On June 12, 2026, Portugal approved Form 63, for the GIR.
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