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International - Pillar Two Quarterly Update (12 November 2025 – 17 February 2026)

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International
  • Australia:
    • The Australian Taxation Office (ATO) updated its guidance on the global and domestic minimum tax on 23 January 2026 to address the side-by-side agreement adopted by the OECD Inclusive Framework (IF) on 5 January and its implications.
    • Technical refinements to the global and domestic minimum tax regime, released on 5 January 2026, introduce minor amendments to align the rules with OECD guidance.
    • A legislative instrument issued on 22 December 2025 sets out the filing exemptions for Pillar Two returns.
  • Austria: An ordinance published on 30 December 2025 contains rules for submitting the GIR (called the “minimum tax report” in Austria).
  • Bahamas: All in-scope entities in the Bahamas must register using the DMTT notification Form 24 by 31 March 2026.
  • Bahrain: A guide published on 31 December 2025 provides additional details on registration requirements for newly established entities, including timelines, when a registration application is considered submitted and when the 120-day registration period begins. The tax authorities have also updated the FAQs on the Domestic Minimum Top-up Tax. 
  • Barbados: A guidance note published by the Revenue Authority on 11 February 2026 announces an extension of the deadline for the initial top-up tax registration from 26 February 2026 to 6 March 2026. In-scope taxpayers complying with the new deadline will not be subject to any penalties.
  • Belgium:
    • As from 2026, in-scope entities making an advance payment of the IIR must do so individually for each group entity using the MyMinfin portal. This change was announced in a press release dated 9 February 2026.
    • A bill published on 30 December 2025 introduces a series of changes and clarifications to Belgium’s global minimum taxation rules.
  • Cabo Verde: The 2026 budget introduces a 15% global minimum tax for CEs of MNEs or large national groups with revenues of EUR 750 million or more in at least two of the four preceding fiscal years. The tax applies as from 1 January 2026 to income included in the UPE’s consolidated financial statements and is calculated based on the ETR. Separate legislation and regulations will set out the operation and procedures for settlement and collection of the minimum tax. 
  • Canada: On 30 January 2026, the government updated its guidance on the global minimum tax to address filing obligations, including information needed for filing and deadlines.
  • European Union: The European Commission published a notice on 12 January 2026 acknowledging the side-by-side arrangement adopted by the OECD IF on 5 January and confirming its status as a qualifying safe harbour under the EU global minimum taxation directive.
  • Finland:
    • Tax returns relating to the global minimum tax may be submitted via the MyTax portal of the tax authorities starting 30 January 2026, according to a recent announcement. In-scope groups will need to file a set consisting of three reports within 15 months after the end of the accounting period: a notification of the filing CE, the top-up tax return and the GIR. The first due date is 30 June 2026.
    • A public consultation is being held on proposed changes to the global minimum tax law that would allow taxpayers to request an advance ruling regarding the application of the Pillar Two rules, the introduction of a general anti-avoidance rule and adoption of the side-by-side package adopted by the OECD IF on 5 January. If adopted, the changes would become effective by 31 March 2026 and generally apply retroactively as from 1 January 2026.
    • Guidance released by the tax authorities on 20 January 2026 focuses on the calculation of the global ETR and the national top-up tax, including examples of the calculations, and also contains clarifications of the  substance-based deduction.
  • France: The tax authorities published new guidance on the global minimum tax rules and the GIR in December 2025.
  • Germany: Regulations that apply as from 29 December 2025 address filing dates and procedures and the exchange of the GIR.
  • Guatemala: The OECD announced on 12 January 2026 that Guatemala has joined the IF. As a member of the IF, Guatemala is committed to the implementation of the minimum BEPS standards, as well as the two-pillar solution to address the tax challenges arising from the digitalisation of the economy. The IF now has 148 member jurisdictions.
  • Hong Kong:
    • Phase One of the Pillar Two portal launched on 19 January 2026, enabling in-scope entities to submit their top-up tax notification forms electronically. Notification forms are due within six months of the end of a fiscal year. The next phase is expected to go live by the fourth quarter of 2026.
    • Updated guidance issued on 8 January 2026 confirms that Hong Kong has obtained transitional qualified status for its IIR, HKMTT and QDMTT safe harbour as from 1 January 2025.
  • Ireland: An e-brief published on 18 December 2025 updates the Tax and Duty Manual Part 04A-01-01A (Guidance on Pillar Two – Registration), including an extension of the registration deadline to 28 February 2026 for in-scope entities whose first fiscal year ends in 2024, and updates relating to inactive/dormant entities, dissolved entities and entities without an active tax registration. An e-brief published on 8 January 2026 confirms the pro rata approach when computing allocation keys under the UTPR with respect to a merged entity.
  • Isle of Man: An order that applies as from 1 January 2026 requires domestic filing entities of MNE groups to enroll in the government's online Pillar Two portal. An entity appointed as a domestic filing entity of an MNE group before 1 January 2026 and that was not enrolled by that date must be enrolled by 30 June 2026.
  • Israel: The parliament announced on 29 December 2025 that it approved the Global Minimum Corporate Tax for Multinational Groups Law 2025. The legislation includes a QDMTT but no IIR or UTPR. The QDMTT applies from 1 January 2026 and includes compliance obligations. Returns are due within 15 months after the end of the year (18 months for the first year) and in-scope entities must submit a notification to the tax authorities within 90 days following the end of the year in which they become subject to the QDMTT. The Ministry of Finance will be issuing regulations for the implementation of the new rules.
  • Italy: On 6 February 2026, the tax authorities published the return form and related instructions qualifying CEs must use to declare and pay top-up tax. The declaration must be submitted electronically; the authorities’ portal will open on a date announced by the tax authorities.
  • Japan: The government announced on 23 January 2026 that it will be amending its global minimum tax rules to incorporate the side-by-side package adopted by the OECD IF on 5 January, including the side-by-side safe harbour, the one-year extension of the transitional CbCR safe harbour, the substance-based tax incentive safe harbour and the UPE safe harbour. The announcement does not mention the simplified ETR safe harbour.
  • Korea:
    • On 19 January 2026, the Ministry of Economy and Finance announced forthcoming revisions to the Korea’s global minimum tax rules, including measures on the calculation of the QDMTT, how it is allocated to Korean CEs and reporting obligations.
    • The Ministry announced on 5 January 2026 that Korea would adopt the Pillar Two side-by-side package adopted by the OECD IF on the same date, with the necessary changes incorporated into future tax bills.
  • Luxembourg: The tax authorities released the forms for registration and filing of the domestic top-up tax return and GIR on 6 January 2026. MNE groups that fall within the scope of the rules for calendar year 2024 must complete the registration and filing requirements by 20 June 2026.
  • Malaysia: Guidance and FAQs published on 3 February 2026 provide clarifications on calculation of the domestic top-up tax, accounting requirements, filing obligations and safe harbour conditions.
  • Netherlands:
    • In a 5 January 2026 letter to parliament, the Ministry of Finance addressed the side-by-side arrangement agreed to by the IF. The letter outlines some key aspects of the arrangement and notes that—while the arrangement is necessary—it is expected to result in an annual revenue loss for the Netherlands but that the arrangement will be implemented into domestic law during 2026.
    • A decree published on 23 December 2025 includes changes to the implementing decree for the Minimum Tax Act, such as rules governing deferred tax liabilities, new formulas for allocating covered taxes across entities and PEs, rules for allocating corrected deferred tax movements, etc. The revised rules generally apply retroactively as from 31 December 2023.
  • OECD:
    • On 5 January 2026, the OECD IF published the side-by-side package,” which includes new safe harbours and the agreed upon side-by-side system.
    • The OECD updated its central record of jurisdictions’ domestic Pillar Two legislation with transitional qualified status on 1 December 2025. The lists in the central record cover jurisdictions’ implementation of the DMTT and IIR and assess whether a jurisdiction’s QDMTT satisfies the additional criteria for the QDMTT safe harbour to apply.
  • Portugal: An order (Portuguese only) published on 12 December 2025 extends the initial deadline for submitting the registration declaration for the global minimum tax regime. The standard deadline is within nine months after the end of the fiscal year, but this was extended to within 12 months after the end of the fiscal year for the first fiscal year an MNE group becomes subject to the regime. The order also extends the submission deadline to within 15 months following the end of the fiscal year for CEs whose fiscal year ended between 31 December 2024 and 31 March 2025.
  • Qatar: On 12 February 2026, the General Tax Authority announced the implementation of a chapter in the Income Tax Law, which establishes the rules for applying the global and domestic minimum tax.
  • Romania: A draft order published on 9 February 2026 includes clarifications on how deferred tax should be reflected in the accounting books by CEs.
  • Singapore:
    • Regulations published on 30 December 2025 address the designation of filing entities for purposes of Singapore's Pillar Two measures and establish recordkeeping requirements for both the multinational top-up tax and the domestic top-up tax.
    • The tax authorities released guidance on registering for the MNE top-up tax and domestic top-up tax. Under the relevant legislation, all in-scope MNE groups are required to register for the two taxes and the GIR, with the registration process commencing in May 2026. The UPE of an MNE group (or designated representative) must notify the Comptroller of Income Tax by submitting the group’s information through an online registration form.
  • Slovak Republic: The Ministry of Finance is preparing a draft bill to amend the country’s global minimum tax rules to take account of the side-by-side package adopted by the OECD IF on 5 January 2026. The tax authorities have released notification form templates for taxpayers to fulfil their top-up tax notification obligations. The forms will be available to taxpayers for e-filing from 1 April 2026.
  • Slovenia: A notice released on 6 February 2026 outlines the main reporting obligations arising under Slovenia’s global minimum tax rules:
    • A domestic top-up tax return must be submitted regardless of whether a tax liability arises for a specific fiscal year. The deadline is 30 June 2026 for the fiscal year ended 31 December 2024.
    • If a taxpayer fails to submit a GIR by 30 June 2026, it must provide information on the group entity that will file an information return in Slovenia or file abroad for an exchange of information with Slovenia.
    • A separate top up tax calculation is necessary where a taxpayer has a top up tax liability under the IIR or UTPR.
  • South Africa: 
    • The South African Revenue Service published guidance on 28 January 2026 that sets out the rules for filing a GIR and the submission of XML data. The measures are found in the Business Requirement Specification (BRS).
    • On 19 December 2025, the South African Revenue Service published a guide on the registration and notification requirements under the country’s Pillar Two rules.
  • Sweden: The Ministry of Finance presented a bill on 27 January 2026 that would amend the domestic global minimum tax rules relating to the tax procedure governing the minimum tax and to incorporate IF updates to the GIR.
The bill also includes proposals for changes resulting from the GloBE Model Rules. The measures are expected to become effective on 1 May 2026.
  • Thailand: The government has taken a series of steps and actions relating to the top-up tax and is expected to adopt additional measures based on the side-by-side arrangement adopted by the OECD IF on 5 January 2026 (see the tax alert on the BDO Thailand website).
  • Turkey: A final General Communiqué published on 26 December 2025 details the application of the domestic minimum top-up tax, compliance and the GIR requirements. On 13 January 2026, the ministry of finance extended the deadline to submit the minimum tax return from 15 January to 28 January 2026.
  • Uruguay: Legislation introducing the domestic complementary minimum tax applies for fiscal years starting on or after 31 December 2025. A decree published on 29 December (in Spanish only) addresses the treatment of fiscal stability clauses that were effective before the introduction of the minimum tax and provides for an exemption from it (in whole or in part) for MNEs benefitting from fiscal stability under the Free Trade Zone Law or specific government contracts. On 30 January 2026, the tax authorities announced the launch of a new website for entities that fall within the scope of the domestic complementary minimum tax.
  • Zimbabwe: The 2026 National Budget, enacted through the Finance Act 2025 on 29 December 2025, includes the adoption of a minimum consolidated annual turnover threshold of EUR 750 million to facilitate the application of the DMTT and a requirement for in-scope entities to submit information on the group’s consolidated annual turnover to the Zimbabwe Revenue Authority on an annual basis.
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