Eye on Pillar 2:
Updates and Insights
Corptax Eye on Pillar 2 is your hub for recent Pillar 2 developments
and what they mean for you. Check back often for the latest news and perspectives.
Update: New OECD guidance adds Side-by-Side Safe Harbor for
U.S.-Parented MNEs (effective 2026); 2024–2025 obligations remain.
On January 5, 2026, the OECD announced new administrative guidance on Pillar 2 global minimum tax requirements that will affect U.S.-parented multinational enterprises (MNEs).
What this means for you:
- Safe from IIR/UTPR: The guidance introduces a Side-by-Side (SbS) safe harbor that exempts U.S.-parented multinationals from IIR and UTPR top-up taxes for fiscal years beginning on or after 1.1.26.
- No Relief for Tax Years 2024 and 2025: Because the SbS safe harbor is effective only for fiscal years beginning on or after January 1, 2026, U.S.-parented multinationals remain subject to IIR and UTPR for 2024 and 2025, where foreign constituent entities have top-up tax exposure.
- Reporting Requirements Remain Intact: For tax years 2024 and 2025, U.S.-parented multinationals must still prepare the GloBE Information Return (GIR) to be filed and shared across foreign jurisdictions.
- Additional Rules: The guidance also includes additional safe harbors that begin with tax years 2026 and 2027, while extending the transitional safe harbor through tax year 2027. While these additional safe harbors are intended to reduce compliance complexities, this relief begins in tax year 2026 and does not provide relief for the 2024/2025 tax periods.
- No Change to QDMTT: The new guidance has no impact on QDMTT filing requirements, which are becoming the norm across most jurisdictions.
Bottom line: Expanded safe harbors may reduce future exposure, but they do not eliminate the need for extensive data, jurisdiction-level analysis, or defensible reporting. Companies still must:
- Centralize data and run repeatable calculations to support safe harbor eligibility and compliance
- Prepare and file the required GIR across relevant jurisdictions within 18 months
- Manage local QDMTT requirements as more jurisdictions adopt domestic minimum taxes
- Monitor rule changes and local adoption, as relief depends on prior-year results and jurisdiction implementation
Corptax GMT Meets Your Current and Future Pillar 2 Needs
CSC Corptax® GMT delivers end-to-end Pillar 2 capabilities in a single, integrated platform—enabling safe harbor qualification and QDMTT analysis, top-up tax calculations, scenario modeling, and GIR reporting. Don’t mistake expanded safe harbors for exemption; compliance burden remains substantial.
It’s critical to take action, prioritize filings, and prepare. Contact Mike Lemons to assess your readiness and map next steps for 2026 obligations.
Actively tracking QDMTT, notification, and GIR obligations across 60+ jurisdictions—unique deadlines, formats, and filing complexities
Below, explore key requirements and how we help streamline compliance with schema-aligned XML, audit-ready reporting, and broad jurisdictional support—all built to keep pace with evolving filing demands.
QDMTT Details by Country
Vietnam (due 12/31/2025)
Calculate and report QDMTT obligations in line with Vietnam’s anticipated adoption of the OECD Model Rules. This includes Safe Harbor provisions, Covered Taxes, and jurisdictional blending logic. While doing so, organize jurisdictional data to support review and data entry through Vietnam’s local filing portal as guidance becomes available.
Türkiye (due 1/15/2026)
Automate QDMTT preparation using logic tailored to Türkiye’s hybrid application of Pillar 2, factoring in domestic minimum tax rules, deferred tax asset treatment, and Qualified Domestic Top-up Tax mechanics. For tax year 2024, Corptax GMT helps you organize and validate QDMTT data to facilitate review and filing through Türkiye’s e-Declaration Portal. This approach supports compliance today while keeping teams prepared as guidance continues to evolve.
Belgium (due 6/30/2026)
Review and validate QDMTT data using embedded logic aligned with Belgium’s QDMTT rules. This includes pre-filing validation and top-up tax estimation based on local financial data and adjustments, so you’re ready to file once Belgium releases the finalized XML schema—without relying on external tools or manual formatting.
Corptax GMT helps you:
- Automate filings with built-in, country-specific logic
- Generate schema-aligned XML reports to reduce manual work and risk
- Rely on a repeatable, audit-ready processes to meet deadlines with confidence
For more information, reach out to Mike Lemons.
CSC Corptax Pillar 2 Solutions — Built for Rapid Response
Count on Corptax to deliver powerful solutions aligned with your evolving Pillar 2 needs.
Latest Enhancement: New GMT GloBE Reports
Leverage key reports mirroring the OECD's latest structure and calculations required for
GIR compliance.
Using Proprietary Tech to Accelerate Updates
Corptax leverages advanced automation to identify differences and release updated schemas, quickly.
Timeliness and Communication
We’ll provide ongoing schema updates and solution refinements throughout 2025 and keep you informed.
Next Steps
With our eyes on Pillar 2, we’re looking out for you! We’re closely monitoring developments, planning for new guidance, and ensuring Corptax GMT keeps you ahead.
- Check back soon for updates covering expected developments.
- Future Enhancements: We will continue to refine our solutions, reflecting new requirements as they are defined.
Explore Pillar 2 Resources
CSC Corptax Global Minimum Tax Software
Solution
Strategic Pillar 2 Collab: FM, Corptax, and BDO
Webinar
Plan for Global Minimum Tax (GMT)
Info Sheet
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