OECD Releases New Pillar Two Guidance, Updated GIR And Framework For Legislative Reviews

On 11 September 2026, the OECD/G20 Inclusive Framework released a new Pillar Two package aimed at supporting the consistent implementation and administration of the Global Minimum Tax (GloBE Rules). The package consists of (i) a new set of Administrative Guidance, (ii) a revised GloBE Information Return (GIR), and (iii) a framework for the peer review of domestic Pillar Two legislation.

New Administrative Guidance

The new Administrative Guidance addresses two specific topics. First, it confirms that taxes that apply only where a taxpayer is subject to a Qualified IIR or UTPR in another jurisdiction (so-called "Explicitly Conditional Taxes") will generally not qualify as Covered Taxes for GloBE purposes. The Inclusive Framework also announced that further guidance on other potentially discriminatory tax features is expected before the end of 2026. Second, the guidance clarifies the operation of the QDMTT Safe Harbour where local financial accounting standards are used and fiscal