Pillar 2 Developments Tracker
Track changes and adoption by jurisdiction.
OpenYour hub for Pillar 2 research. Access country analysis, global trackers, domestic-law views and research tools.
Jurisdiction-by-jurisdiction materials and deliverables.
Track changes and adoption by jurisdiction.
OpenGenerate stakeholder-ready PDF outputs.
OpenCountry guides and practical implementation detail.
OpenAnalysis and explainers across key issues.
OpenCross-jurisdiction views and domestic-law tracking.
Browse domestic legislation across jurisdictions.
OpenTrack domestic adoption of OECD Administrative Guidance.
OpenMonitor QDMTT implementation in domestic law.
OpenTrack safe harbour adoption and domestic law status.
OpenWorkflow tools for faster analysis and delivery.
Ask questions and accelerate research workflows.
OpenTooling for member workflows and delivery.
OpenFind content and move through Pillar 2 materials faster.
OpenAssess Transitional CbCR Safe Harbour eligibility by tested jurisdiction and export structured outputs.
OpenAutomated tool to determine eligibility for the Simplified ETR Safe Harbour.
OpenLatest Developments
On July 28, 2026, Monaco issued a draft law to to implement a QDMTT for fiscal years beginning on or after 31 December 2026.
On July 23, 2026, Canada released a narrowly targeted amendment to its Global Minimum Tax Act (“GMTA”) that would broaden the circumstances in which an intra-group financing or investment arrangement must be neutralised when applying the transitional Country-by-Country Reporting (“CbCR”) safe harbour.
Luxembourg has published draft legislation that would implement the OECD’s January 2026 Side-by-Side package, introduce the permanent Simplified ETR Safe Harbour and extend the Transitional CbCR Safe Harbour.
Bill No. 8795 was deposited in the Luxembourg Chamber of Deputies on July 17. 2026. It would amend the Law of 22 December 2023 on minimum effective taxation, which implemented the EU Pillar Two Directive and introduced Luxembourg’s income inclusion rule, undertaxed profits rule and QDMTT.
On July 16, 2026 Barbados issued a guidance note: ‘Qualified Domestic Minimum Top-up Tax (QDMTT): Transitional Rule for Fiscal Year 2024 – Transitional Application of Section 5(4) of the Corporation Top-Up Tax Act, 2024-16‘. This provides guidance on the application of its Conditional QDMTT where some Barbados constituent entities are held through a parent applying an income inclusion rule (IIR), while other Barbados entities in the same multinational group are not exposed to an IIR or UTPR.
On July 13, 2026, the UK government published draft Finance Bill 2026–27 legislation implementing the OECD’s January 2026 Side-by-Side package. The proposals introduce the permanent Simplified ETR Safe Harbour, extend the Transitional CbCR Safe Harbour, provide special treatment for qualifying substance-based tax incentives and implement both the Side-by-Side and Ultimate Parent Entity Safe Harbours.
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