South Africa Issues a Guide to Filing Pillar Two Returns: GMT01/GMT02
On June 1, 2026, SARS issued the ‘Guide to Submit Global Minimum Tax (GMT) Returns on eFiling’ which explains how MNE groups must access, complete, amend and support South African Global Minimum Tax filings through eFiling.
Belgium Issues a Royal Decree for its 2024 QDMTT Return
On June 1, 2026, the Belgian Official Gazette published the Royal Decree of May 25, 2026 determining the 2024 Pillar Two QDMTT Return
Czech Republic Issues Decree No. 68/2026 Coll on the Pillar Two filing framework
On May 20, 2026, the Czech Republic issued Decree No. 68/2026 Coll which prescribes the content structure and electronic format for the Czech Pillar Two tax return and the Czech Pillar Two information return. The decree became effective on 21 May 2026.
Sweden clarifies first Pillar Two filing approach: practical implications for GIR, central filing and Swedish top-up tax compliance
The Swedish Tax Agency has updated its public guidance on Sweden’s implementation of the Pillar Two global minimum tax regime.
Germany’s Pillar Two Amendments in its Draft Annual Tax Act 2026
Germany’s Federal Ministry of Finance published the Draft Annual Tax Act, 2026 on May 19, 2026. Key changes include implementation of aspects of the OECD January 2026 Side-by-Side Package.
The OECD’s May 2026 Pillar Two guidance: central GIR filing, 52–53-week fiscal years and the updated Central Record
On May 18, 2026, the OECD provided three Pillar Two updates: a common understanding among jurisdictions relating to late-filing penalties, further Administrative Guidance on the Transitional UTPR Safe Harbour for 52–53-week fiscal years, and an update to the Central Record.
Indonesia Issues Regulation PER-6/PJ/2026 on Pillar Two Administrative Requirements
On May 4, 2026, Indonesia Issued Regulation PER-6/PJ/2026 on Pillar Two Administrative Requirements.
Canada issues its Budget 2025 Implementation Act, No. 2: UTPR, New Safe Harbours and OECD Administrative-Guidance Alignment
On May 6, 2026, Canada issued its Budget 2025 Implementation Act, No. 2 into Parliament. This includes numerous amendments to its Global Minimum Tax Regime.
Switzerland Issues a Pillar Two Consultation on the OECD Article 9.1 DTA Guidance
On May 6, 2026, Switzerland opened a consultation on amendments to the Swiss Minimum Taxation Ordinance, to delay the Swiss application of the OECD January 2025 Administrative Guidance on Article 9.1 of the GloBE Model Rules for one year.
Australia’s May 2026 proposed Pillar Two amendments: the CbCR safe harbour extension and related technical fixes
On May 1, 2026, Australia issued the draft Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2026 Measures No. 2) Rules 2026 for consultation. This includes a one-year extension to the Transitional CbCR safe-harbour and a number technical amendments to the Australia’s Pillar Two rules
