Contents
General
The Spring Finance Bill 2023 (Finance (No. 2) Bill) was published yesterday (March 23, 2023), along with its Explanatory Notes. The Bill includes provisions to implement key aspects of the Pillar Two Global Minimum Tax for accounting periods beginning on or after 31 December 2023.
This follows the original draft legislation published on July 20, 2022.
The Undertaxed Profits/Payments Rule was not included in the Bill, however this is not unexpected as it was announced in the Autumn Statement that this will apply no earlier than accounting periods beginning on or after 31 December 2024.
The draft legislation is very comprehensive and, as expected, covers relevant aspects of the OECD Model Rules, Commentary and other Published Guidance.
In particular it, provides for an Income Inclusion Rule (named the Multinational Top-Up Tax) and a Domestic Top-Up Tax (which is likely to be a Qualified Domestic Minimum Top-Up Tax).
The UK Bill is the most comprehensive law we have seen to date to implement the Pillar Two Global Minimum Tax. It closely follows the OECD Model Rules and reflects the latest guidance, including aspects of the OECD Safe Harbours Guidance and the Administrative Guidance.
It is worth noting at the outset that Section 255 of the Bill specifically refers to the OECD Model GloBE Rules and Commentary (including the OECD Examples) and directly applies them in various aspects of the application of the Multinational Top-Up Tax.
In addition, it applies ‘any further commentaries or guidance published from time to time by the OECD that are relevant to the implementation of the Pillar Two model rules’.
This would, therefore, include the OECD Administrative Guidance that will itself be included in an updated version of the OECD Commentary.
Application
If you haven’t got a subscription you can sign up below
On August 8, 2026, Mauritius issued its QDMTT regulations to implement its QDMTT.
On 3 August 2026, Korea’s Ministry of Finance and Economy released its 2026 Tax Reform Proposal. Among its international tax measures are proposed amendments intended to implement significant elements of the OECD/G20 Inclusive Framework’s January 2026 Pillar Two Side-by-Side Package.
Decision No. 12 of 2026 introduces a seven-month registration period, transitional deadlines and a five-year notification regime for UAE entities within the domestic minimum top-up tax framework.
Qatar’s General Tax Authority (GTA) activated its Global and Domestic Minimum Tax registration service through the Dhareeba tax platform on 2 August 2026.
On 30 July 2026, the Portuguese Government published Portaria No. 318/2026/1, approving Model 64 – the Pillar Two Top-up Tax Return – and its accompanying completion instructions. The Ministerial Order entered into force and took effect on 31 July 2026.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Monaco for accounting periods beginning on or after December 31, 2026.
Monaco has published draft legislation introducing a Qualified Domestic Minimum Top-up Tax (QDMTT) for multinational enterprise groups. The measure is contained in Bill No. 1129 on the minimum taxation of multinational enterprise groups, dated 14 July 2026 and received by Monaco’s Conseil National on 28 July 2026.
On July 23, 2026, Canada has released a proposed targeted amendment to its Global Minimum Tax Act 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.
On July 17, 2026, Bill No. 8795 was deposited in the Luxembourg Chamber of Deputies. This 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.
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.
On July 13, 2026, the UK government published draft Finance Bill 2026–27 legislation implementing the OECD’s January 2026 Side-by-Side package.
On July 1, 2026, Australia issued the Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2026 Measures No. 2) Rules 2026. This incorporates elements of the OECD Agreed Administrative Guidance issued in December 2023, June 2024 and January 2026.
This website is not affiliated with or related to the OECD. We provide independent insights and analysis on the OECD Two-Pillar Solution
© 2026 OECDPillars.com
All Rights Reserved