Pillar 2 Developments Tracker
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OpenLatest Developments
On April 17, 2026 Brazil opened a public consultation to amend RFB Normative Instruction No. 2,228/2024, which implements Brazil’s domestic minimum top-up tax through the Additional CSLL (QDMTT). Brazil is seeking to align its domestic rules with the OECD January 2026 Administrative Guidance, specifically the new Substance-based Tax Incentive Safe Harbour.
On April 9 and 10, 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.
The first publication, KG:911:2026:2, addresses when an entity qualifies as a joint venture under article 1.2 of the Dutch Minimum Tax Act 2024. The second publication, KG:911:2026:3, addresses whether the Act’s location rule and the five-year transitional rule for the under-taxed profits rule apply when calculating top-up tax for a joint venture group.
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.
On April 8, 2026, Germany issued a Draft Regulation which included a list of jurisdictions with qualifying status for the purposes of the IIR, UTPR, QDMTT and the QDMTT Safe Harbour.
On April 8, 2026, Italy’s Tax Authority issued an Order to approve the detailed technical specifications for the submission of Italy’s GloBE returns.
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