Pillar Two Tools & Analysis

Domestic Pillar Two Implementation

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Latest Pillar 2 Developments

September 17, 2025: The Netherlands – On September 16, 2025, The Netherlands Cabinet issued a Draft Bill for the Second Amendment to the Minimum Tax Act to implement the June 2024 and January 2025 OECD Administrative Guidance (as well as the EU DAC 9 proposals).

September 17, 2025: Japan – Japan has launched its Multinational Enterprise Information Reporting Portal for filing Pillar 2 returns. Returns related to global minimum tax for the fiscal year starting from April 1, 2024, are accepted from September 16, 2025. 

September 12, 2025: Switzerland – On September 12, 2025, the Swiss Federal Council issued the Federal Decree on the Approval of the Multilateral Agreement of the Competent Authorities on the Exchange of Global Anti-Base Erosion Declarations, which ratifies the OECD GIR MCAA.

September 12, 2025: Poland – On September 11, 2025, the Polish Ministry of Finance issued the draft Pillar 2 notifications and top-up tax returns for consultation.

September 11, 2025: Ireland – On September 8, 2025, Ireland released Revenue eBrief No. 170/25 with detailed information on the registration process.

September 9, 2025: Vietnam – On September 8, 2025, the Ministry of Finance announced it is to issue a draft resolution to amend its global minimum tax law to exempt from the QDMTT entities implementing BOT power projects with a Government Guarantee.

September 4, 2025: Portugal – On September 2, 2025, Portugal issued Ordinance No. 290/2025/1 which includes the format for the Pillar 2 registration form (Form 62).

September 3, 2025: Czech Republic – On September 2, 2025, Act No. 316/2025 Coll was published in the Official Gazette to amend the Minimum Tax Act for various aspects of the OECD Administrative Guidance as well as filing dates, QDMTT amendments and amending the Safe Harbour rules.

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

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