A Review of Turkey’s Draft Pillar Two Returns
April 9, 2026
On April 8, 2026, the Turkish Revenue Administration published draft versions of its Pillar Two Tax Returns/Notifications.
The December 2022 Safe Harbour and Penalty Relief Guidance provided for a Simplified Calculations Safe Harbour. The aim being to reduce or simplify the number of computations and adjustments an MNE is required to make under the GloBE Rules.
The only simplified calculations that have currently been developed by the OECD are the Non-Material Constituent Entity (NMCE) Simplified Calculations.
A number of jurisdictions already include the Simplified Calculations Safe Harbour in their GloBE legislation (see our Pillar Two GloBE Guides), including:
– Austria
– Bulgaria
– Germany
– Ireland
– Luxembourg
– Romania
– UK
The December 2023 OECD Administrative Guidance provides further information on the NMCE Simplified Calculations (for the Simplified Calculations Safe Harbour).
NMCEs are constituent entities of an MNE Group that are not consolidated on a line-by-line basis in the MNE Group’s audited consolidated financial statements solely for size or materiality grounds. It also includes any permanent establishments of these entities (providing the Main Entity is itself an NMCE.)
It should be noted that an entity will only be considered a NMCE if an external auditor has agreed that the entity does not meet the materiality standards and has been excluded from the consolidation process on those grounds.
Where an entity’s revenue exceeds EUR 50 million, the entity will only be an NMCE if its financial accounts are prepared in accordance with an Acceptable Financial Accounting Standard or an Authorised Financial Accounting Standard.
Given the significant practical difficulties MNEs may have in obtaining accurate reporting figures for NMCEs (as they aren’t included in the consolidated accounts), NMCEs can benefit from the following simplifications:
– The GloBE revenue and GloBE income of an NMCE is the total revenue of the NMCE as determined in accordance with the relevant CbC regulations.
– The adjusted covered tax of a NMCE is the income tax accrued as determined in accordance with the relevant CbC regulations (note that this excludes any deferred tax expenses, adjustments for non-current items and provisions for uncertain tax liabilities).
Relevant CbC Regulations are the Country-by-Country Reporting Regulations of the UPE Jurisdiction or of the surrogate parent entity jurisdiction if a Country-by-Country Report is not filed in the UPE Jurisdiction.
If the UPE jurisdiction does not have CbC requirements and an MNE Group is not required to file a CbC Report in any jurisdiction, Relevant CbC
Regulations are the OECD BEPS Action 13 Final Report and the OECD Guidance on the Implementation of Country-by-Country Reporting.
These simplified figures are then used for three tests under the Simplified Calculations Safe Harbour.
On April 8, 2026, the Turkish Revenue Administration published draft versions of its Pillar Two Tax Returns/Notifications.
On April 3, 2026, Liechtenstein enacted an amendment to its Pillar Two Regulation (LGBl. 2026 Nr. 114). This includes amendments to the Pillar Two regime including providing for aspects of the January 2026 Side-by-Side tax package.
A guide to Vietnam’s Pillar Two compliance flow: the reporting-entity notification, special tax registration, the GIR information package embedded in the Vietnamese filing package, and the QDMTT and IIR return packages filed through the tax e-filing system.
This guide focuses on Austria’s GIR filing architecture as published by the Austrian Federal Ministry of Finance (BMF): access to FinanzOnline, filing channels, the Austrian national XML overlay on top of the OECD GIR, correction mechanics, and transport/protocol handling for implementation.
On March 31, 2026, Japan enacted its 2026 Tax Reform Package. This includes amendments to the Pillar Two regime including providing for aspects of the January 2026 Side-by-Side tax package (excluding the Simplified ETR Safe Harbour) and the January 2025 OECD Administrative Guidance.
On March 25, 2026, Australia issued the Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2026 Measures No. 1) Rules 2026, to amend its Pillar Two rules to incorporate aspects of the OECD Administrative Guidance for DMTT purposes.
On March 25, 2026, Sweden issued a draft law to include new Pillar Two simplification rules including the Side-by-Side Safe Harbour, UPE Safe Harbour, and other additions to Sweden’s top-up tax rules
A guide to South Africa’s current public Pillar Two compliance package: eFiling subscription for Global Minimum Tax, the six‑month information / notification step, the GloBE Information Return (GIR), and the South Africa‑specific XML rules that sit on top of the OECD GIR structure
A practical guide to Hong Kong’s Registration, top-up tax notification, GIR / top-up tax return architecture, and current Hong Kong-specific data-format rules
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