The Netherlands opens Pillar Two Filing from June 2026
April 24, 2026
The Netherlands has announced the opening of its Pillar Two filing from June 2026.
Article 10 of the OECD Model Rules defines an entity as either:
– a legal person (except an individual); or
– any arrangement that prepares separate financial accounts.
Note that the First Set of OECD Administrative Guidance also excludes government agencies (both central and local government) that carry out government functions.
The first limb above would generally catch foundations, whilst the second would catch trusts.
This means that trusts and foundations are squarely within the Pillar Two rules and could be a low-taxed entity, an intermediate entity/partially owned parent entity or even an ultimate parent entity (UPE).
Under Article 1.4.1 of the OECD Model Rules, a UPE for the Pillar Two rules is:
Whether a trust is a UPE is an important consideration as (1) in many cases the UPE is required to apply the income inclusion rule to account for top-up tax and (2) the definition of an MNE group hinges on the relationship between the group companies and the UPE.
For instance, take this scenario:
Determining if the trust was the UPE could result in all companies then potentially being within the scope of the Pillar Two rules (subject to any specific exclusions etc). Aside from the application of Pillar Two to the group, the trust could then be liable to account for top-up tax.
This in itself could create issues.
The definition of a group in the Pillar Two rules relies on accounting principles so that there is a group if there is a requirement to prepare consolidated financial statements.
Whilst a trust or foundation may not usually have to prepare consolidated financial statements under an accounting standard, the Pillar Two rules go further.
Article 10 of the OECD Model Rules states that if no consolidated financial statements are prepared a deeming provision applies so that the entity must prepare hypothetical consolidated financial statements as if it was required to prepare them in accordance with an Authorised Financial Accounting Standard that is either an Acceptable Financial Accounting Standard or another financial accounting standard.
As such, a trust or foundation would need to determine if it would be required to prepare accounting standards under an accounting standard.
This would again depend on accounting principles.
Under IFRS for instance, there is a requirement to consolidate if the trust or foundation possesses power over the parent entities, has exposure to variable returns from its involvement with them and has the ability to use its power over them to affect its returns.
The Netherlands has announced the opening of its Pillar Two filing from June 2026.
A guide to Norway’s three compliance workstreams for Pillar Two (suppleringsskatteloven): the GloBE Information Return (GIR), the foreign-filer notification, and the Norwegian top-up tax return.
A review of the remedial timing amendment that aligns New Zealand’s GloBE incorporation rules with the OECD’s January 2026 Side-by-Side Package.
On April 17, 2026, the Brazil opened up a consultation on proposed changes to its QDMTT regime to implement the Substance-based Tax Incentives (SBTI) Safe Harbour.
On 9 and 10 April 2026, the Dutch Tax Administration’s Pillar Two Knowledge Group published two administrative positions on the treatment of joint ventures under the Dutch Minimum Tax Act 2024.
A guide to Italy’s three-track Pillar Two process: the reporting-entity notification, the DAC9/GIR (Comunicazione Rilevante), and the domestic GloBE Return (Dichiarazione fiscale Globe) with related F24 payments.
A guide to Australia’s Pillar Two filing. It covers the separate local GIR XML filing, the foreign lodgement notification, and the Combined Global and Domestic Minimum Tax Return (CGDMTR), including the Australian IIR/UTPR tax return and Australian DMT tax return. It also flags the main ATO validation rules and the software / API points that matter if you are building or testing a filing process.
A guide to Spain’s three-part Pillar Two workflow: model 240 (group/filing notification), model 241 (GIR-DAC9 information return), and model 242 (top-up tax self-assessment).
On April 7, the Swiss Federal Tax Administration issued Communication-031-E-2026-f and Communication-030-E-2026-f to apply the OECD January 2025 and January 2026 Administrative Guidance
This website is not affiliated with or related to the OECD. We provide independent insights and analysis on the OECD Two-Pillar Solution
© 2026 OECDPillars.com
All Rights Reserved