June 2026 was one of the busiest months yet for the global minimum tax. The OECD turned the GloBE Information Return into a hard, machine-readable filing task, several jurisdictions moved to adopt the January 2026 Side-by-Side package, and a wave of countries granted filing relief as the first compliance cycle went live. For UAE and wider Gulf groups, these are not distant European headlines. They shape how you prepare data, when you file, and how your UAE Domestic Minimum Top-up Tax position connects to the rest of the group.
Here is what you will take away from this guide:
- What actually changed in June 2026, separated into confirmed facts and interpretation.
- Why the OECD GIR XML guidance turns Pillar Two into a data and IT project.
- How the Side-by-Side package and jurisdictional moves affect group planning.
- What filing relief in Portugal, Belgium, and Turkey signals for your own calendar.
- A practical action checklist for UAE decision-makers in Dubai and beyond.
Throughout, we mark the difference between confirmed legal facts, professional interpretation, and illustrative examples, so you know exactly where the rules end and judgment begins.
The big picture: Pillar Two moved from statute to operations
Confirmed legal fact: the global minimum tax is built on the OECD Global Anti-Base Erosion Model Rules. These rules require large multinational groups to calculate income and taxes on a jurisdictional basis and pay a top-up where the effective tax rate falls below 15 percent. The wider design is set out on the OECD Global Minimum Tax page.
Professional interpretation: through 2024 and 2025, Pillar Two was largely a modelling and legislation story. June 2026 marked the shift to live operations. The returns are now real, the filing formats are defined, and tax authorities are publishing forms and granting extensions. For any in-scope group, that means the compliance clock is running and data readiness cannot wait.
For UAE groups specifically, the UAE Domestic Minimum Top-up Tax (DMTT) sits inside this global machine. The UAE Ministry of Finance Top-up Tax page confirms the DMTT applies for financial years starting on or after 1 January 2025 to constituent entities of groups with annual global revenues of EUR 750 million or more in at least two of the four preceding financial years.
What happened in June 2026 in Pillar Two
Confirmed legal fact: several distinct developments landed during June 2026. The table below summarises the main ones, which we then explain in detail.
| Development | What it was | Who it affects |
|---|---|---|
| OECD GIR XML guidance | Practical guidance for the first GloBE Information Return filing and exchange cycle | Every in-scope group filing a GIR |
| Side-by-Side adoption | Legislative or consultation moves in Norway, Singapore, Netherlands, Isle of Man | Groups with entities in those jurisdictions |
| Filing relief | Deadline extensions in Portugal, Belgium, and Turkey | Groups with entities in those countries |
| Cyprus qualified IIR | EU confirmation that Cyprus has a Qualified Income Inclusion Rule | Groups with Cypriot entities or parents |
| Belgium return forms | Final QDMTT and IIR returns for FY2024 and FY2025 | Groups filing in Belgium |
Professional interpretation: no single item rewrites the rules, but together they confirm that the first filing cycle is under way and that jurisdictions are racing to finalise mechanics. UAE groups with any European or Gulf footprint should treat June 2026 as a signal to lock their processes now.
The OECD GIR XML Schema guidance: the month's most relevant change
Confirmed legal fact: the GloBE Information Return is the standardised global disclosure of group structure, elections, safe harbours, and jurisdictional calculations. During June 2026, the OECD published guidance on using the GIR XML Schema for the first filing and exchange cycle, introducing practical fixes, workarounds, and the switch-off of certain validation rules for 2026 filings.
Why does this matter? The return is not a narrative memo. It is a structured data product that must be produced in a specific machine-readable format, validated, and exchanged between tax authorities.
Professional interpretation: this is the point where Pillar Two becomes an IT and data programme as much as a tax exercise. If your source data is not mapped to the GIR fields, you cannot pull the numbers together at the last minute. The XML format leaves no room for a rushed spreadsheet.
The wider framework that supports this operational push is captured in the OECD Global Minimum Tax Implementation Toolkit, which sets out best-practice implementation steps for tax administrations and, by extension, the environment groups must file into.
UAE implications of the GIR guidance
Confirmed legal fact: in the UAE, the Pillar Two Information Return (P2IR) is the domestic term for the standardised OECD GloBE Information Return. Under Article 15.4 of the UAE framework, the P2IR is due no later than 15 months after the last day of the reporting fiscal year.
Professional interpretation: the OECD XML guidance directly affects UAE filers because the P2IR follows the same OECD architecture. UAE finance teams should confirm the FTA submission process for the relevant year and build controlled data lineage now. SBC's guide to the UAE Pillar Two Information Return explains the filing population and routes, while the UAE Pillar Two data readiness checklist maps the fields to owners and source systems.
The January 2026 Side-by-Side package and June 2026 adoption moves
Confirmed legal fact: in January 2026, the OECD Inclusive Framework agreed a Side-by-Side package. According to the OECD Global Minimum Tax page, the package includes a Simplified ETR safe harbour, a one-year extension of the Transitional CbCR Safe Harbour, a new Substance-Based Tax Incentive safe harbour, and new safe harbours for groups headquartered in jurisdictions that meet minimum taxation requirements. It also preserves the primacy of Qualified Domestic Minimum Top-up Taxes.
During June 2026, four jurisdictions advanced this package at different legislative stages.
| Jurisdiction | Action | Stage |
|---|---|---|
| Norway | Draft legislation implementing the Side-by-Side package | Proposed |
| Singapore | Consultation on amending the Multinational Enterprise (Minimum Tax) Act 2024 | Consultation |
| Netherlands | Consultation on a draft safe harbours bill | Consultation |
| Isle of Man | Amendment order enacting the Side-by-Side package | Enacted |
Professional interpretation: consultations and draft bills are not yet law, but they signal the direction of travel, and retroactive application is common. UAE groups should map where their entities sit against these proposals now rather than waiting for final enactment. A group with a Norwegian, Singaporean, Dutch, or Isle of Man entity may see its safe-harbour options change for periods already under way.
For how safe harbours interact with the UAE regime, see SBC's guide on UAE Pillar Two safe harbours.
Filing relief and deadline extensions: Portugal, Belgium, and Turkey
Confirmed legal fact: several authorities eased deadlines during June 2026 while leaving the underlying tax liabilities unchanged.
- Portugal allowed certain constituent entities to file Pillar Two information and assessment returns without penalties until 30 September 2026, although the relief did not extend to registration declarations.
- Belgium extended its FY2024 GIR notification deadline to 30 September 2026, with its electronic portal expected to go live from 1 July 2026.
- Turkey moved its GloBE return filing and payment deadline from 30 June 2026 to 31 July 2026.
Professional interpretation: these extensions confirm that even well-resourced tax authorities found the first cycle demanding. That is a useful reality check for UAE groups. If European administrations needed more time to finalise portals and forms, a UAE group should not assume its own first cycle will be smooth without early preparation.
Illustrative example: imagine a UAE-parented group with subsidiaries in Belgium and Turkey and a Free Zone principal in Dubai. The group now has three different local timelines to track, plus the UAE P2IR and Top-up Tax Return dates. Treating these as one deadline would be a serious control failure. Each needs its own owner, data cut-off, and evidence trail.
Belgium return forms: why final forms matter
Confirmed legal fact: during June 2026, Belgium published the final QDMTT and IIR returns applicable to FY2024 and FY2025.
Professional interpretation: final forms are not a formality. They confirm the exact data fields, elections, and reconciliations a group must produce. When a jurisdiction finalises forms, groups can stop estimating and start populating real returns. For UAE groups with Belgian entities, this is the trigger to confirm that the group data model produces every field the Belgian forms demand.
The Cyprus qualified IIR point under the EU framework
Confirmed legal fact: during June 2026, the European Commission confirmed through an updated FAQ that all EU Member States must treat Cyprus as having a Qualified Income Inclusion Rule under the EU Pillar Two Directive, even though Cyprus does not appear on the OECD Central Record.
Professional interpretation: this creates a subtle but important divergence. A group might check the OECD Central Record, find Cyprus absent, and draw the wrong conclusion about where top-up tax is collected. The EU framework and the OECD record can point in different directions for the same jurisdiction.
Why this matters for Gulf groups: recognition determines which jurisdiction has the right to collect top-up tax. If your group has a Cypriot parent or intermediate holding company, the qualified status of its IIR affects the order in which charging rules apply to lightly taxed profits, including UAE Free Zone profits. Keep a dated snapshot of both the OECD Central Record and the relevant EU position with each filing.
Why these developments matter for UAE and Gulf groups
June 2026 reinforced two priorities for groups operating in the UAE and the Gulf.
First, the GIR is now a hard, format-specific deliverable. Data readiness is the binding constraint, not the headline tax rate.
Second, the treatment of Gulf regimes is still settling. Confirmed legal fact: the UAE has implemented the DMTT and has not introduced an Income Inclusion Rule at this stage, as the Ministry of Finance Top-up Tax page confirms. Recognition of Gulf QDMTTs across other jurisdictions can still shift, so groups with Qatari, Bahraini, Omani, Kuwaiti, or other regional entities should track recognition decisions closely.
Professional interpretation: a UAE-headquartered group can have no UAE Income Inclusion Rule exposure yet still face IIR or UTPR consequences through foreign parents or subsidiaries. "The UAE has no IIR" is not the same as "the group has no IIR exposure." June's Cyprus and Side-by-Side developments are a reminder that the global map keeps moving.
The UAE interpretive base: Ministerial Decision No. 96 of 2026
Confirmed legal fact: the UAE anchors its DMTT interpretation to the OECD materials through Ministerial Decision No. 96 of 2026. Issued on 22 June 2026, it adopts the 2026 Consolidated Commentary, the Administrative Guidance Central Record, and the January 2025 GloBE Information Return, and it repealed Ministerial Decision No. 88 of 2025.
Professional interpretation: this matters for reading June 2026 developments correctly. Because the UAE adopts the OECD Central Record on a rolling basis, a qualified-status change abroad can feed straight into UAE modelling. SBC's analysis of Ministerial Decision No. 96 of 2026 explains why groups need a standing process to track these changes rather than waiting for a single annual release.
Connecting June 2026 to UAE DMTT, registration, and the GIR
The June developments do not change UAE law, but they sharpen three UAE workstreams.
Registration
Confirmed legal fact: the FTA has launched a dedicated Pillar Two Top-Up Tax Registration service on EmaraTax, and the wider Corporate Tax registration environment is set out on the FTA Corporate Tax Registration page and the FTA Corporate Tax page. Registration is the gateway to every later obligation.
Professional interpretation: a group can register as an individual entity or through a Domestic Designated Filing Entity. SBC's UAE Pillar Two registration guide walks through the EmaraTax steps and the authorisation trap of collecting letters before the application opens.
The GIR and the compliance calendar
Confirmed legal fact: for a calendar-year group whose first in-scope year ended 31 December 2025, the transitional registration deadline is generally 30 November 2026, the P2IR is generally due 31 March 2027, and the first Top-up Tax Return and payment are generally due 30 June 2027.
| UAE obligation | General rule | FY2025 calendar-year illustration |
|---|---|---|
| Top-up Tax registration | Within 7 months after the first in-scope year; transitional rule for early-ending periods | 30 November 2026 |
| Pillar Two Information Return | 15 months after the reporting fiscal year-end | 31 March 2027 |
| First Top-up Tax Return and payment | 15 months, extended to 18 months for the transition year | 30 June 2027 |
Professional interpretation: do not merge the P2IR date with the Top-up Tax Return date. The information return falls three months before the first tax return for a calendar-year group. SBC's UAE Pillar Two compliance calendar sets out how these interact, and the UAE Pillar Two DMTT guide provides the wider scope and calculation context.
Data readiness
Professional interpretation: the June 2026 GIR XML guidance makes data readiness the defining task. The GIR turns calculations into structured data, so entity names, tax identification numbers, classifications, elections, and amounts must be internally consistent and capable of validation. Lock the source-data mapping months before the filing window opens.
Transfer pricing alignment
Confirmed legal fact: cross-border transactions between constituent entities must be recorded at arm's length under both the UAE Corporate Tax framework and the GloBE rules. The arm's length principle is set out in the OECD transfer pricing framework.
Why this connects to June 2026: transfer pricing determines where group profit sits, and Pillar Two tests the tax on that profit in each jurisdiction. When jurisdictions finalise forms and safe-harbour rules, the profit allocation feeding those returns must be consistent with your transfer pricing file.
Professional interpretation: a year-end true-up that moves profit into or out of the UAE can change the jurisdictional effective tax rate and the top-up result. Keep intercompany agreements, transfer pricing policies, the GIR, and the UAE DMTT return telling one consistent story. SBC's analysis of transfer pricing and the UAE DMTT result works through how a true-up changes the outcome, and the Transfer Pricing service page sets out how the workstreams combine.
Practical business implications
Bringing the month together, here is what June 2026 means in practice for a UAE or Gulf finance function.
- The GIR is a data deliverable, so treat it as an IT and controls project with named owners.
- Safe-harbour options can change mid-cycle as jurisdictions adopt the Side-by-Side package, so re-screen your entity map.
- Foreign filing relief does not remove UAE obligations, and it rarely removes local notification duties abroad.
- Recognition divergence, as with Cyprus, means you should check both the OECD record and the relevant local or EU position.
- Registration remains the gateway, and a nil top-up does not usually remove the duty to register.
Illustrative example: a Gulf group treats a safe harbour as final based on a pre-2026 memo. The January 2026 package extended the Transitional CbCR Safe Harbour by one year, so the group's eligibility window is different from what the old memo assumed. Relying on the outdated document risks either an overpayment or a filing correction. Always verify the applicable fiscal-year window against current guidance.
Common mistakes to avoid
- Treating the P2IR and the Top-up Tax Return as one deadline with one owner.
- Assuming a foreign GIR filing removes every UAE obligation, including notification.
- Reading the OECD Central Record once and never re-checking recognition changes.
- Ignoring the EU versus OECD divergence on jurisdictions such as Cyprus.
- Pulling GIR data together late, when the XML format demands controlled lineage.
- Reusing a pre-2026 safe-harbour memo without checking the extended windows.
- Assuming "the UAE has no IIR" means the group has no IIR or UTPR exposure anywhere.
- Letting the transfer pricing file and the Pillar Two model describe the same transaction differently.
A practical action checklist for UAE groups
Use this as a working plan through the current cycle.
- Confirm scope: verify the EUR 750 million revenue history and document the tested fiscal year.
- Map the entity population: cover every UAE mainland, Free Zone, branch, JV, and permanent establishment, plus foreign entities in jurisdictions moving on the Side-by-Side package.
- Lock the GIR data mapping: align every field to a source system and owner using the OECD architecture.
- Track jurisdictional deadlines: build one controlled calendar covering UAE dates plus any relief in Portugal, Belgium, Turkey, and elsewhere.
- Re-screen safe harbours: test eligibility against the extended windows and the current guidance.
- Check recognition: keep dated snapshots of the OECD Central Record and relevant EU positions, including Cyprus.
- Confirm registration: complete UAE Pillar Two registration and decide the DDFE or individual approach.
- Align transfer pricing: reconcile the local file, policies, GIR, and DMTT return before filing.
- Assign governance: set preparer, reviewer, and sign-off roles, with contingency plans for foreign-filing reliance.
- Refresh regularly: update the plan after any acquisition, disposal, restructuring, or new jurisdictional rule.
For the wider context on why the UAE rate does not translate into a simple top-up, see SBC's article on 9 percent Corporate Tax versus the 15 percent Pillar Two floor. You can also review the full June 2026 Pillar Two updates roundup, browse the insights hub, or explore the full range of services.
Frequently asked questions
What did the OECD publish on the GloBE Information Return in June 2026?
Confirmed legal fact: 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 for 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 to 31 July 2026. In each case, the underlying tax liabilities were unchanged.
Is Cyprus treated as having a Qualified IIR?
Yes. The European Commission confirmed that all EU Member States must treat Cyprus as having a Qualified Income Inclusion Rule under the EU Pillar Two Directive, even though Cyprus does not appear on the OECD Central Record. Groups should check both sources when assessing where top-up tax is collected.
Does June 2026 change UAE DMTT law?
No. The June developments are mostly OECD and non-UAE jurisdictional moves. UAE DMTT law continues to apply for financial years starting on or after 1 January 2025, and its interpretation runs through Ministerial Decision No. 96 of 2026. The developments sharpen how UAE groups prepare data and coordinate across jurisdictions.
Why do the June 2026 updates matter for Gulf groups specifically?
Recognition of Gulf QDMTTs and the treatment of regional regimes are still settling. Groups with entities in the UAE, Qatar, Bahrain, Oman, or Kuwait should monitor recognition decisions, because they influence where top-up tax is collected and how filing and credit positions work.
Does a foreign GIR filing remove UAE obligations?
Not automatically. A qualifying foreign filing can discharge local P2IR filing where the exchange conditions are met, but UAE entities may still need to notify the FTA of the filer's identity and location, and the UAE Top-up Tax Return and payment remain domestic obligations.
What is the single most useful first step after June 2026?
Lock your GIR source-data mapping. Because the XML format is strict and validated, groups that map data to owners and systems early avoid the last-minute scramble that the June extensions abroad revealed.
Conclusion
June 2026 confirmed that Pillar Two is now an operational reality. The OECD GIR XML guidance made the information return a strict data deliverable, the Side-by-Side package began moving into domestic law, and filing relief in Portugal, Belgium, and Turkey showed how demanding the first cycle is. For UAE and Gulf groups, the message is consistent: prepare data early, track separate deadlines, re-screen safe harbours, and keep transfer pricing and Pillar Two aligned.
Start now by mapping your entities, locking your GIR data, and confirming your UAE registration and calendar. To pressure-test your group's position across UAE DMTT, the GIR, and transfer pricing, explore SBC's Corporate Tax and Transfer Pricing services, or contact the SBC team for a review tailored to your Dubai and Gulf footprint.