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
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A guide to to Australia’s Pillar Two filing. It covers the separate local GIR XML filing, the foreign lodgement notification, and the Combined Global and Domestic Minimum Tax Return (CGDMTR), including the Australian IIR/UTPR tax return and Australian DMT tax return. It also flags the main ATO validation rules and the software / API points that matter if you are building or testing a filing process.
A guide to Spain’s three-part Pillar Two workflow: model 240 (group/filing notification), model 241 (GIR-DAC9 information return), and model 242 (top-up tax self-assessment).
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, 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
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