BDO Corporate Tax News

International - Pillar Two Quarterly Update (18 February – 13 May 2026)

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International
  • Australia:
    • The Australian Taxation Office announced on 5 May that covered MNE groups can file their GIRS, as well as their global and domestic minimum tax returns, through the ATO online portals. The first filings are due by 30 June 2026.
    • Updated guidance released on 12 March confirms the effective dates of the IIR, QDMTT and UTPR; expands the treatment of certain types of entities and arrangements; explains how the rules interact with Australia's tax consolidation regime; and compliance obligations.
    • Guidance released on 25 March 2026 addresses the Pillar Two treatment of tax-consolidated group restructurings.
  • Bahamas: The Department of Inland Revenue has outlined the steps for completing the DMTT registration and filing for in-scope Bahamas entities of MNE groups. DMTT filing and payment for fiscal years starting in 2024 are due on 30 June 2026.
  • Belgum:
    • The filing deadline for the top-up tax under the IIR and the QDMTT has been extended. The deadline for the IIR for reporting years starting on 1 January 2025 and ending 31 May 2025 is extended to 30 September 2026 (also applicable to  reporting years starting 31 December 2023 and ending 31 December 2024, and those ending 28 February 2025). The QDMTT deadline for reporting years starting on or after 31 December 2023, and reporting years ending between 1 January 2024 and 30 September 2025 is extended from 17 November 2025 to 30 September 2026.
    • New draft versions of the supplementary national tax returns and explanatory notes for 2024 and 2025 and the draft XSD schema were published on 23 March 2026.
  • Brazil:
    • A public consultation is underway on the incorporation of the substance-based tax incentive safe harbour into Brazil’s Pillar Two rules.
    • A normative instruction published 30 March 2026 revises the rules governing the payment of the “Additional CSLL,” including a requirement that amounts payable be reported in a declaration of federal tax debits and credits relating to the sixth month after the fiscal year-end.
  • Curaçao: The Minister of Finance announced on 13 April 2026 that the government has established its position on the implementation of the Pillar Two framework, following the publication of the side-by-side package. The government has decided not to introduce a QDMTT or a UTPR, but it will introduce an IIR that is expected to apply retroactively as from 1 January 2025.
  • Finland:
    • Guidance published on 13 April 2026 addresses the transitional and permanent safe harbor rules.
    • Guidance published 9 April clarifies the Minimum Tax Act, including identification of UPEs, intermediate parent entities and in-scope CEs; residence determination; exempt groups; and rules for calculating revenue thresholds in restructurings.
    • Minor technical amendments published on 24 March 2026 introduce a general anti-avoidance rule and a provision allowing taxpayers to request an advance ruling on the application of the Pillar Two rules.
  • France: The tax authorities updated their GIR user guide, indicating that the platform for filing the GIR for 2024 GIRS is open 4 May 2026 - 30 June 2026, with a test platform available from 8 April 2026 for submission of test files.
  • Germany: A draft bill published on 20 March 2026 addresses the exchange of GIRs under the Multilateral Competent Authority Agreement on the Exchange of GloBE Information.
  • Greece: A decision issued 12 March 2026 sets out the format, content and filing procedure for the notification required with respect to the top-up tax information return. The filing entity must submit the notification electronically through the Greek portal within 15 months of the end of the relevant reporting fiscal year (18 months for the first in-scope year).
  • Hungary: On 20 February 2026, the tax authorities released expanded reporting obligations for in-scope domestic group entities. Entities must include the name, tax number and country code of the group entity responsible for submitting the GIR, indicate whether they are filing independently or as the designated local organisation and report any changes in the designated local organisation.
  • Indonesia: A regulation published on 4 May 2026 sets out the procedures for compliance with the minimum tax, including notification, registration, filing various returns, etc.
  • Ireland: An eBrief published 24 March 2024 announced Pillar Two updates to two Tax and Duty Manuals, including changes relating to DAC9, the secondary collection mechanism for UTPR and QDTT liabilities, taxpayer recordkeeping obligations, penalties and various technical updates. 
  • Italy:
    • Guidance published 8 and 9 April 2026 sets out the technical specifications for the electronic submission of the annual global minimum tax return and the schema and procedures for submitting the GIR.
    • The tax authorities released software for in-scope companies to submit the notification form identifying the group member responsible for filing the GIR and the global minimum tax return, which must be filed even if tax is not due.
  • Korea: Guidance released on 28 April 2026 contains a summary of the global minimum tax filing requirements, i.e., the GIR, the foreign constituent entity report and the top-up tax return.
  • Liechtenstein: Amendments to the Pillar Two regulation published on 3 April 2026 implement the safe harbours under the side-by-side arrangement for tax years starting on or after 1 January 2026.
  • Malta: In March 2025, the Tax and Customs Administration announced an updated version of the guidance on the global minimum tax.
  • Montenegro: Pillar Two legislation published on 10 March 2026 introduces a QDMTT aligned with the EU directive and the OECD GloBE rules. Montenegro will not introduce an IIR or UTPR at this time. Implementation guidance will be forthcoming. Although the legislation does not include a date from which the global minimum tax rules apply, this is expected to be 1 January 2026.
  • Netherlands: The Pillar Two Knowledge Group has released several positions on the application of the Minimum Tax Act 2024.
  • Oman: A public consultation has been held on draft executive regulations to the Pillar Two rules.
  • Poland:
    • A draft regulation released on 12 March 2026 sets out the detailed data requirements for the GIR, including information on the MNE group and its structure, the reporting CE, safe harbours, etc.
    • A bill published on 13 February 2026 incorporates the OECD Administrative Guidelines from June 2024 and January 2025 regarding deferred tax assets and certain reserves, as well as administrative procedures, accounting standards and safe harbour provisions in the QDMTT.
  • Kuwait: Covered taxpayers may make an advance payment of the minimum tax for tax periods ending on or before 31 March 2026. To opt in, taxpayer must apply to the Ministry of Finance before 31 May 2026 and estimate the tax due. The DMTT must be paid in a lump sum by 30 June 2026, constituting the advance payment.
  • OECD: Updated FAQs on the global minimum tax were released in April 2026 that include clarifications on the new simplification measures. The OECD has also published a Global Minimum Tax Implementation Toolkit (the Toolkit) to assist tax administrations in applying the Pillar Two rules.
  • Romania: An order published on 24 February 2026 approves the top-up tax information return and requires in-scope entities to file the return.
  • Singapore: The tax authorities updated their guidance on registration under the Pillar Two rules.
  • Slovenia: A test environment for filing domestic top-up tax returns, top-up tax returns under the IIR and the UTPR opened on 6 May 2026.
  • South Africa: Registration for the global minimum tax on the South African Revenue Service eFiling portal opened on 16 March 2026.
  • Sweden: A consultation was held on a proposed R&D tax incentive based on expenditure for R&D personnel and how the incentive would be treated under the OECD Pillar Two rules. Two proposals are under consideration: (i) a super deduction equal to 200% of salary costs for R&D personnel, resulting in a total deduction of 300% of those costs; or (ii) a refundable tax credit equal to 20% of salary costs for R&D personnel. If enacted, the measure would apply as from 1 January 2027.
  • Turkey: The tax authorities have published detailed guidance on the application of the domestic minimum corporate income tax that explains the scope and calculation of the tax and compliance obligations.