Netherlands proposes new Pillar Two safe harbours in its 2027 Tax Plan
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.
OECD Publishes September 2026 Pillar Two Guidance
On September 11, 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 Amends Fiscal Stability Compensation for its QDMTT
Uruguay’s presidential decree dated 31 August 2026 replaces the conditional QDMTT payment waiver in Decree No. 325/025 with a compensation mechanism. Article 1 requires in-scope constituent entities allocated QDMTT in Uruguay to comply with its QDMTT obligations and pay the tax; article 7 repeals the earlier decree.
Qatar Issues GTA Decisions Nos. 17-22 of 2026 on Pillar Two
Qatar has published six decisions dealing with currency conversion, simplified reporting, the Transitional CbCR Safe Harbour, non-material constituent entities, designated local entities and registration.
Slovakia Approves Draft Pillar Two Amendments Implementing the New Tax-Incentive Safe Harbour
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.
Cyprus Consults on Amendments to its QDMTT
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.
Germany publishes Pillar Two recognition list in amended Minimum Tax Regulation
On August 7, 2026, Germany published a regulation that gives domestic legal effect to a jurisdiction-by-jurisdiction list of qualifying Pillar Two jurisdictions.
Mauritius issues Detailed QDMTT Regulations
On August 8, 2026, Mauritius issued its QDMTT regulations to implement its QDMTT.
Korea’s 2026 Tax Reform Proposal: Implementing the OECD Pillar Two Side-by-Side Package
On 3 August 2026, Korea’s Ministry of Finance and Economy released its 2026 Tax Reform Proposal. Among its international tax measures are proposed amendments intended to implement significant elements of the OECD/G20 Inclusive Framework’s January 2026 Pillar Two Side-by-Side Package.
UAE FTA establishes Pillar Two registration and deregistration deadlines
Decision No. 12 of 2026 introduces a seven-month registration period, transitional deadlines and a five-year notification regime for UAE entities within the domestic minimum top-up tax framework.
