
Pillar 2 Country Analysis
Pillar 2 Articles
Latest Developments
On December 31, 2025, Croatia published the Ordinance on automatic exchange of information in the field of taxation in the Official Gazette. This implements DAC9 and also provides the Croatian GIR.
On January 7, 2026, Turkey opened its QDMTT Return filing portal.
On January 6, 2026, Luxembourg opened up its pillar 2 filing portal for registration, GIRs and Pillar 2 returns. This includes the XMLs and user guides. All filing is electronic via XML at myguichet.lu
On January 5, 2025, the OECD published guidance on the side-by-side tax package. This includes:
-Introduction of a new Simplified ETR Safe Harbour
-Extension of the Transitional CbCR Safe Harbour
-Introduction of a new Substance-based Tax Incentive safe harbour.
-New Side-by-Side and UPE Safe Harbours
On December 29, 2025, Israel’s Parliament approved the law to introduce a QDMTT from 2026.
On December 23, 2025, the Austrian Official Gazette published the Tax Amendment Act 2025 which includes amendments to the Minimum Tax Act for the December 2023, June 2024 and January 2025 OECD Administrative Guidance, EU DAC 9 implementation and other sundry changes.
On December 23, 2025, Korea enacted Law number 21215 to implement the 2026 Tax Reform. This includes a QDMTT from January 1, 2026.
On December 30, 2025, IRAS issued further details on the Pillar 2 registration process. The registration portal is to be open from May 2026, however, a draft registration form and explanatory notes have been issued. NB there is also a requirement to disclose companies incorporated or registered in Singapore that had shifted their tax residency from Singapore to a foreign jurisdiction after November 30, 2021.
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