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
OECD Releases its Global Minimum Tax Implementation Toolkit
On April 30, 2026, the OECD released its Global Minimum Tax Implementation Toolkit. The Toolkit is directed primarily at tax administrations and tax policy officials implementing the global minimum tax
South Africa’s 2026 Pillar Two amendments: an Article-by-Article Analysis
South Africa’s April Pillar Two amendments are focused on implementing the June 2024 OECD Administrative Guidance (sections 63–65 of the Taxation Laws Amendment Act, 2026 and section 25 of the Tax Administration Laws Amendment Act, 2026).
Finland Issues Detailed Guidance on the GIR XML
In April 2026, Finland issued detailed guidance on the Finnish implementation of the GloBE Information Return (GIR)
Croatia Issues a Draft Ordinance to Provide for Pillar Two Administrative Amendments
On April 10, 2026, Croatia issued a Draft Ordinance to provide for various administrative aspects of its Pillar Two regime.
