- Antigua & Barbuda: The Ministry of Legal Affairs, Public Safety, and Labour has published draft legislation that would fulfil Antigua & Barbuda’s commitment to implement the Pillar Two initiative.
- Australia: The Australian Taxation Office has announced three priority areas for guidance: (i) Pillar Two filing obligations and the ATO's transitional approach; (ii) the ability of taxpayers to request private rulings and the “new decline to rule” provision for Pillar Two; and (iii) other technical and administrative aspects of Pillar Two.
- Bahrain: The Minister of Finance and National Economy has established a tax objections committee for the DMTT law, which is charged with overseeing DMTT-related objections and ensuring fair application of the rules and the tax authorities have published a DMTT registration manual, which provides step-by-step instructions on the registration process, including how to use the NBR’s online portal for DMTT compliance.
- Belgium: The government has published a draft tax form that will be used by companies subject to the QDMTT (and that is aligned with the GIR template). Groups will have to be registered in Belgium to submit the QDMTT form, with the first filing deadline being 30 November 2025.
- Finland: The tax authorities have released guidance on the general principles and goals of the Pillar Two rules and the types of taxes that must be taken into account when calculating the effective tax rate.
- Ireland: An eBrief published on 8 May 2025 updates the Tax and Duty Manual - Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union - Administration to confirm that an exemption applies for a securitisation vehicle in respect of the UTPR and QDTT group recovery. Another e-brief published on 17 February clarifies the rules relating to the calculation of deferred tax assets.
- Italy: A Ministerial Decree published on 6 March 2025 sets out the procedure for in-scope taxpayers to notify the tax authorities that the GIR will be filed centrally in another jurisdiction. The decree requires entities to submit relevant information, including the identification of local entities designated to file on their behalf and include all required information.
- Japan: The 2025 tax reform package published on 31 March 2025 includes the introduction of a DMTT and a UTPR that are aligned with the OECD Pillar Two rules. The UTPR and QDMTT will apply for fiscal years starting on or after 1 April 2026. Japan enacted an IIR on 28 March 2023, which applies to fiscal years starting on or after 1 April 2024.
- Kenya: The Finance Bill 2025 presented to the National Assembly on 30 April 2025 includes a proposal to require payment of the DMTT by the end of the fourth month after the end of the relevant income year.
- Liechtenstein: The tax authorities have launched a public consultation on potential changes to the GloBE Act relating to the exchange of GloBE tax and information returns.
- Netherlands: The government plans to introduce for parliamentary approval measures that would incorporate into the Minimum Taxation Act 2024 the remaining aspects of the December 2023, June 2024 and January 2025 OECD Administrative Guidance.
- OECD: The OECD released an updated Consolidated Commentary to the Global Anti-Base Erosion Model Rules on 9 May 2025, which incorporates the additional agreed administrative guidance documents approved by the Inclusive Framework since publication of the previous consolidated Commentary in 2024. The update includes policy clarifications and a new annex for the central record of legislation with qualified status for a transitional period.
- Qatar: The government published a law on 27 March 2025 that amends the Income Tax Law to introduce rules that are consistent with the OECD GloBE Rules. The measures include an IIR, a UTPR and a QDMTT that apply to MNE groups operating in Qatar with consolidated annual revenue of EUR 750 million or more in two of the preceding four fiscal years. The IIR, UTPR and QDMTT apply for fiscal years starting on or after 1 January 2025. The amended rules incorporate the OECD commentary and administrative guidance, as well as relevant safe harbours. The government is expected to issue Executive Regulations and/or other guidance on implementation and operation of the Pillar Two rules.
- Spain: Regulations published on 2 April 2025 contain measures for calculating the tax base and adjusted covered taxes, filing the GIR and rules that apply when the fiscal year of the UPE differs from that of the CEs.
- Sweden: The Ministry of Finance is holding a consultation on proposals to incorporate the OECD’s June 2024 guidance into the domestic measures, as well as guidance on the cross-border allocation of taxes.
- Switzerland: The government has launched a consultation on proposed amendments to the Pillar Two ordinance that would add rules on how in-scope groups are to file their GIR returns and for the automatic exchange of GIRs between the Swiss tax authorities and tax authorities in other jurisdictions.
The tax authorities launched OMTax—a web-based application developed jointly by the cantons and the federal tax authorities and operated by the Swiss tax conference—on 2 January 2025. OMTax will enable in-scope Swiss entities to electronically register for purposes of the Pillar Two rules in OMTax and file their tax returns (click here for an overview of the new app by BDO in Switzerland).
- United Arab Emirates: The Ministry of Finance has announced that a ministerial decision published on 28 March 2025 adopts the full sets of OECD guidance and relevant commentary released up to January 2025. The guidance applies retroactively as from 1 January 2025.