June 2026 was a busy month for the global minimum tax. Jurisdictions across Europe, Asia and the Americas moved to embed the OECD's January 2026 Side-by-Side package into domestic law, the OECD published practical guidance for the first GloBE Information Return (GIR) filings, and several countries granted filing relief as the first compliance cycle got under way. This roundup pulls the month's developments into one view for in-scope groups.
Key takeaways
- The OECD published GIR XML Schema guidance for the first filing and exchange cycle, adding practical workarounds and validation adjustments for 2026 filings.
- Four jurisdictions moved on the Side-by-Side package: Singapore and the Netherlands opened consultations, Norway proposed amendments, and the Isle of Man enacted it via an amendment order.
- Filing relief was granted in Portugal (penalty-free to 30 September 2026), Belgium (GIR notification to 30 September 2026) and Turkey (GloBE return to 31 July 2026).
- The EU confirmed Cyprus as having a Qualified IIR and published a Pillar Two Compliance Manual for MNE groups.
- Belgium published its final QDMTT and IIR returns for FY2024 and FY2025.
The OECD moves to operational filing
The OECD published guidance on using the GloBE Information Return XML Schema for the first filing and exchange cycle — the month's most widely relevant development. The guidance introduces practical filing solutions, technical workarounds and validation-rule adjustments intended to smooth the initial GIR process during 2026. For any in-scope group, this is the moment Pillar Two becomes an IT and data project as much as a tax one: the return has to be produced in a specific machine-readable format, validated, and exchanged between authorities.
The European Commission complemented this by publishing a Manual for MNE Groups on Global Minimum Tax (Pillar Two) Compliance Obligations, giving jurisdiction-specific guidance across several EU Member States, and by confirming through an updated FAQ that all EU Member States must treat Cyprus as having a Qualified Income Inclusion Rule under the EU Directive — even though Cyprus does not appear on the OECD Central Record.
Side-by-Side adoption spreads
Four jurisdictions advanced the OECD's January 2026 Side-by-Side package during the month, at different stages of the legislative process.
| Jurisdiction | Action | Status |
|---|---|---|
| Norway | Draft legislation implementing the Side-by-Side package | Proposed (4 June) |
| Singapore | Consultation on the Finance (Income Taxes) Bill 2026 amending the Multinational Enterprise (Minimum Tax) Act 2024 | Consultation (9 June) |
| Netherlands | Consultation on a Draft Safe Harbours Bill | Consultation to 14 July (22 June) |
| Isle of Man | Global Minimum Tax (Pillar Two) (Amendment) Order 2026 | Enacted (24 June) |
Norway's proposal spans the full suite — the Side-by-Side, UPE, substance-based tax incentive and simplified ETR safe harbours, plus an extension of the transitional CbCR safe harbour. The Isle of Man went furthest, enacting an order that embeds the OECD Central Record and the 2026 Side-by-Side package into its interpretative framework and expands the Treasury's authority to recognise Qualified Side-by-Side and Qualified UPE regimes.
Consultations and draft bills are not yet law — but they signal the direction of travel. Groups should map where their entities sit against these proposals now, because retroactive application is common and the first filing cycle is already open.
Filing relief and new return forms
Several authorities eased deadlines as the first cycle went live, while leaving the underlying liabilities untouched. Portugal issued Order No. 76/2026-XXV, letting constituent entities with fiscal years ending between 31 December 2024 and 31 March 2025 file their Pillar Two information and assessment returns without penalties until 30 September 2026 — though the relief does not extend to registration declarations. Belgium extended its FY2024 GIR notification deadline from 30 June to 30 September 2026, with its electronic portal expected to go live from 1 July 2026, and Turkey pushed its GloBE tax return filing and payment deadline from 30 June to 31 July 2026.
Some jurisdictions also finalised their forms alongside the extensions. Belgium published the final QDMTT return for Assessment Year 2024 and, later in the month, the final QDMTT and IIR returns applicable to FY2024 and FY2025. Brazil issued IN RFB No. 2,329/2026 to clarify the centralised payment mechanism for its Additional CSLL and address fiscal-year timing mismatches affecting the transitional CbCR safe harbour.
Recognition and alignment updates
HMRC revised Notice 2 on the relevant territories and taxes for its Multinational Top-up Tax and Domestic Top-up Tax, broadly aligning the UK with the OECD Central Record — the month's main recognition development. An apparent inconsistency remains over the effective date of Qatar's QDMTT, a point of direct interest to Gulf groups. Sweden and the Bahamas also refined their regimes, with the Bahamas issuing a DMTT (Amendment) Bill, 2026 expected to take effect on 1 July 2026 subject to enactment.
What Pillar Two means for UAE and Gulf groups
For groups operating in the UAE, June's developments reinforce two priorities. First, the GIR is becoming a hard, format-specific deliverable — the OECD's XML guidance means data readiness cannot wait. Second, the treatment of Gulf regimes is still settling, as the HMRC-versus-Central-Record question over Qatar's QDMTT shows, so groups with Qatari or other regional entities should track recognition decisions closely and keep their international tax and transfer pricing positions aligned across jurisdictions. In practice, SBC locks the GIR source-data mapping months before the filing window opens, since the XML format leaves no room to pull the numbers together at the last minute.
Frequently asked questions
What did the OECD publish on the GloBE Information Return in June 2026?
The OECD released guidance on using the GIR XML Schema for the first filing and exchange cycle. It provides practical filing solutions, technical workarounds and validation-rule adjustments to support the initial GloBE filing process during 2026, effectively turning the return into a defined machine-readable deliverable.
Which countries extended their Pillar Two filing deadlines in June 2026?
Portugal allowed penalty-free filing until 30 September 2026 for certain fiscal years, Belgium extended its FY2024 GIR notification deadline to 30 September 2026, and Turkey moved its GloBE return filing and payment deadline from 30 June to 31 July 2026. In each case the underlying tax obligations were unchanged.
Is Cyprus treated as having a Qualified IIR?
Yes. The European Commission confirmed via an updated FAQ that all EU Member States must treat Cyprus as having a Qualified Income Inclusion Rule under the EU Pillar Two Directive, despite Cyprus not appearing on the OECD Central Record. Cyprus may also receive GloBE Information Returns and participate in DAC9 exchanges.
Why does the Qatar QDMTT point matter for Gulf groups?
Recognition affects where top-up tax is collected. HMRC's updated Notice 2 broadly aligns with the OECD Central Record but shows an apparent inconsistency over the effective date of Qatar's QDMTT. Groups with Qatari entities should monitor how that is resolved, as it can influence their filing and credit positions.
How SBC Tax Consulting can help
SBC keeps in-scope groups current as Pillar Two developments land month by month. We translate OECD and jurisdictional updates into a practical action list, prepare GIR-ready data in the required format, track filing extensions and recognition decisions across the jurisdictions where you operate, and reconcile them with your UAE obligations. Our international tax and tax automation teams keep the moving parts in one place. Contact SBC to stay ahead of the next round of changes.
This publication is for general information only and does not constitute professional advice. Please consult your SBC advisor before acting on any matter covered here.