Trending Now

Australia Issues a Draft Instrument for IIR/UTPR/QDMTT Filing Exemptions

Romania Issues a Draft Law to Amend its Minimum Tax Act

Mauritius Enacts a QDMTT From July 1, 2025

IIRs and DMTTs that don’t yet Qualify Under the OECD August 2025 Update

Pillar Two Tracker

Pillar Two: Safe Harbours

On December 20, 2022, the OECD issued the Safe Harbours and Penalty Relief: Global Anti-Base Erosion Rules (Pillar Two), which includes details of two safe harbours and penalty relief for the Pillar Two GloBE rules. 
 
 The three published reliefs were the:
 
 
Note that the first two are temporary, whereas the Simplified Calculations Safe Harbours are permanent.
 
On July 17, 2023, the OECD issued its Second Set of Administrative Guidance. This included a QDMTT Safe Harbour and a Transitional UTPR Safe Harbour.
 
Whilst the safe harbours/harbors represent a significant simplification for MNEs, qualifying for a safe harbour for a jurisdiction does not exempt an MNE Group from complying with group-wide GloBE requirements such as the requirement to prepare and file its GloBE Information Return. 
 
For information on the domestic implementation of the Safe Harbours, see our GloBE Country Guides. 
 
Picture of Lee Hadnum
Lee Hadnum
Lee is a qualified Chartered Accountant and a former Senior Tax Analyst at Bloomberg Tax. Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.

Latest Articles

australia flag

Australia Issues a Draft Instrument for IIR/UTPR/QDMTT Filing Exemptions

August 27, 2025

On August 27, 2025, the Australian Taxation Office issued a draft legislative instrument (the ‘Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR tax return and Australian DMT tax return) Determination 2025’). This outlines situations when entities within the scope of the Pillar 2 GloBE rules do not need to file an Australian DMT Return or an IIR/UTPR Return.

Read More »
romania flag

Romania Issues a Draft Law to Amend its Minimum Tax Act

August 26, 2025

On August 20, 2025, the Romanian government issued a draft law for consultation. The law proposes amendments to various aspects of the Minimum Tax Act, including for the filing deadline for the designated filing entity nomination, transferable tax credits and the excess negative tax carry forward election.

Read More »
registration

Pillar Two: Domestic Registration Requirements

August 12, 2025

Many jurisdictions will require GloBE registration for administrative purposes, however, the law issued to date has been inconsistent. We outline the GloBE registration obligations from the domestic legislation (enacted and draft) issued to date, with citations and links to relevant laws.

Read More »

This website is not affiliated with or related to the OECD. We provide independent insights and analysis on the OECD Two-Pillar Solution

image showing 'OECDpillars.com logo'
s2Member®

© 2025 OECDPillars 

All Rights Reserved