Transitional Penalty Relief Regime

This is another temporary provision to relax penalties for MNEs in the initial years of the application of the GloBE Rules.
 
It applies for fiscal years beginning on or before December 31, 2026 but not after June 30, 2028, and provides that during this period, no penalties should apply relating to the filing of a GloBE Information Return where an MNE has taken “reasonable measures” to ensure the correct application of the GloBE Rules.
 
This will be at the discretion of tax authorities but the OECD notes that an MNE that can demonstrate that it has acted in good faith to understand and comply with the domestic application of the GloBE Rules and any QDMTT, this is likely to be viewed as taking reasonable measures.

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Liechtenstein Gazettes amendments to the Pillar 2 Law and Regulation

On December 23, 2025, Liechtenstein’s Official Gazette included amendments to the Pillar 2 law and regulation to implement domestically the OECD provisions for the exchange of information in the GloBE Information Return (GIR) under the multilateral agreement between competent authorities on the exchange of GloBE information (GIR MCAA).

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Portugal Extends its Pillar 2 Registration Deadline

Order No. 158/2025 XXV issued on December 12, 2025 provides that for constituent entities whose fiscal year ended between December 31, 2024 and March 31, 2025 the filing deadline for Form 62 (the Pillar 2 Registration Form) is the last day of the 15th month following the end of that fiscal year.

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