Uruguay Enacts DMTT Law and issues a Decree for Exemptions under Tax Stability Agreements
On December 29, 2025, Uruguay’s President issued Decree No. 325/025, to provide for exemptions from the QDMTT for entities covered by a tax stability agreement. Note that Law N° 20446 to enact the QDMTT was published in the Official Gazette on January 8, 2026.
South Korea Enacts 2026 Tax Reform for QDMTT Implementation
On December 23, 2025, Korea enacted Law number 21215 to implement the 2026 Tax Reform. This includes a QDMTT from January 1, 2026.
Sample Excel File for the Simplified ETR Safe Harbour
On January 5, 2026, the OECD Released Guidance on amendments to the Pillar 2 rules for the Side-by-Side Tax Package. This includes a new Simplified ETR Safe Harbour from December 31, 2026 (December 31, 2025 in certain cases). We provide an excel overview for the key elements of the Safe Harbour calculation.
Sample Calculator for the New Substance-based Tax Incentive Safe Harbour
On January 5, 2026, the OECD Released Guidance on amendments to the Pillar 2 rules for the Side-by-Side Tax Package. This includes a new Substance-based Tax Incentive Safe Harbour. This online tool shows how the new safe harbour operates.
New Elections in the OECD Side-by-Side Package
On January 5, 2026, the OECD Released Guidance on amendments to the Pillar 2 rules for the Side-by-Side Tax Package. This article looks at a number of the new elections that arise from this.
OECD Releases Guidance on the Side-by-Side Package
On January 5, 2026, the OECD Released Guidance on amendments to the Pillar 2 rules for the Side-by-Side Tax Package.
OECD Administrative Guidance: Domestic Implementation Matrix
We have tracked the draft and enacted domestic laws issued to date back to both sets of OECD Administrative Guidance in this matrix for our members. This will be constantly updated as new or amended legislation is issued.
Transitional CbCR Safe Harbour: Domestic Implementation Tracker
We track the implementation of key aspects of the Transitional CbCR Safe Harbour in draft and enacted domestic laws issued to date back to the OECD Safe Harbours Guidance and the OECD Administrative Guidance.
Pillar Two: GMT Compliance Forms
We keep track of all domestic Pillar Two forms issued to date, including links to domestic forms and notices for each relevant jurisdiction.
QDMTT: Legislative Tracker
Track the development and application of QDMTTs as they are implemented globally. The OECD Administrative Guidance provides significant flexibility as to their design.
