Filing activity across 34 jurisdictions shows that Pillar Two has become a recurring, multi-form global compliance process
The first major global Pillar Two filing season has moved multinational tax teams from preparation into execution.
Between November 1, 2025 and June 30, 2026, more than 1,700 Pillar Two filings were prepared or submitted through the Orbitax International Tax Platform, with activity recorded across 34 identified jurisdictions.
The filings covered a broad range of obligations, including GloBE Information Returns, GIR notifications, QDMTT returns, IIR top-up tax returns, registrations, and self-assessment returns.
For several years, Pillar Two work focused primarily on interpreting the rules, modeling potential outcomes, testing safe harbors, and preparing the required data. The first major filing deadlines showed that completing the calculation is only the beginning.
Once filing obligations become due, tax teams must turn calculation results into multiple jurisdiction-specific forms, apply local validation rules, manage internal reviews and approvals, navigate authority submission systems, and track the status of each obligation.
Pillar Two is no longer only a technical tax and data challenge. It is now a recurring global compliance process.
Pillar Two compliance extended far beyond the GIR
One of the clearest lessons from the first filing season is that Pillar Two compliance cannot be reduced to a single global return.
GIR notifications and self-assessment returns represented more than 60 percent of recorded filing activity through the Orbitax platform. Registrations, QDMTT returns, IIR returns, and GloBE Information Returns added hundreds of further obligations.
For multinational tax teams, this created a much broader operational challenge than preparing the GIR alone. Teams had to identify every applicable local obligation, coordinate multiple forms from a common data set, meet different deadlines, and respond to jurisdiction-specific submission and validation requirements.
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The promise of a uniform GloBE Information Return initially offered hope for a streamlined Pillar 2 filing process. In reality, it evolved into a complex network of registrations, notifications, top-up tax returns, and local GIRs, with practices varying significantly across jurisdictions. Consequently, identifying and tracking filing obligations for MNEs became a massive undertaking, long before the task of populating the first form even began. Our focus over the past several years has been to empower clients to monitor these obligations, understand filing methodologies, and seamlessly populate all forms via direct links to our GMT calculation — a vision that has now come to fruition.
Jacob Fulton
Head of Quantitative Tax Practice at Orbitax
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Nearly one-third of analyzed filing activity occurred in the final week
The season also confirmed how sharply global compliance activity can compress toward a common deadline.
Of all filings, around 30 percent were created during the final seven days before June 30.
The concentration was particularly pronounced in several jurisdictions. Approximately one-third or more of platform filing activity in the Netherlands, Sweden, Austria, Switzerland, Canada, Germany, and the United Kingdom occurred during the final week.
The surge was not driven by GIRs alone. GIR notifications and self-assessment returns represented almost two-thirds of the identified filing types created during those seven days, showing how local obligations can accumulate alongside the global return.
The pattern will be familiar to tax teams managing complex compliance calendars. Calculations may be substantially complete before the deadline, but filings often remain dependent on final data reviews, internal approvals, local interpretations, and validation results.
As a result, issues that are manageable individually can arrive simultaneously across multiple jurisdictions and filing types.
The practical lesson is that Pillar Two compliance must be designed for peak periods, not average volume. Tax teams need sufficient structure, visibility, and processing capacity to maintain control when filing activity accelerates and real authority systems, data changes, and statutory deadlines converge.
From technical knowledge to filing infrastructure
The first filing season highlighted an important distinction.
A knowledge problem ends when the answer is correct. An infrastructure problem then begins.
More than 1,700 successful filings prepared across a global footprint required more than just correct Pillar Two calculations. It required a process for converting those calculations into the appropriate local forms, applying jurisdiction-specific validation requirements, generating authority-ready output, managing submission channels, and tracking authority responses.
In some jurisdictions, filings could be transmitted directly from the Orbitax platform to the relevant tax authority. In others, the platform generated the required filing output for submission through a government portal.
The submission method differed by country, but the underlying need was consistent: tax teams required a structured way to manage filing obligations from preparation through submission and status monitoring.
For multinational groups, that filing infrastructure can replace a fragmented process built around separate spreadsheets, local forms, email approvals, and country portals with a more consistent global workflow.
Filing activity across 34 identified jurisdictions
Canada and the United Kingdom together accounted for approximately 38 percent of total recorded activity.
The five highest-volume jurisdictions were:
- Canada
- United Kingdom
- Germany
- The Netherlands
- Ireland
Together, these jurisdictions accounted for just over half of the season’s total filing activity.
The remaining volume extended across a much broader group of countries, including Austria, Sweden, Switzerland, Belgium, Vietnam, and many others.
Nearly one-third of recorded activity fell outside the ten highest-volume jurisdictions.
This long tail is an important part of the Pillar Two compliance challenge. Even jurisdictions with relatively limited filing volume require local analysis, form support, validation rules, deadline management, and an appropriate submission process.
The result is a global filing landscape in which activity may be concentrated in several major markets, but operational complexity is distributed across many more.
The work behind each filing
The numbers reflect more than forms generated through a technology platform.
Behind each filing was a tax team working through evolving local requirements, data questions, internal reviews, authority guidance, validation errors, submission procedures, and filing approvals.
The season also required close coordination among multinational tax departments, advisory firms, implementation teams, developers, support professionals, tax authorities and all Orbitax teams.
In several jurisdictions, technical requirements and authority processes continued to evolve as the filing deadlines approached. Tax teams therefore needed to respond not only to the Pillar Two rules themselves, but also to the practical realities of submitting returns through newly introduced systems.
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The volume is important, but the larger story is the coordination behind it. Customers, partners, tax experts, developers, and support teams worked across jurisdictions and time zones to resolve issues as they emerged and keep filings moving. Every validation question, authority response, and successful submission created practical knowledge improving the process for the next filers.
Bianca Kuijper
Chief Operating Officer at Orbitax
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Each filing question and authority response contributed to a growing body of operational knowledge about how Pillar Two compliance works in practice.
Orbitax is incorporating those lessons into its jurisdiction-specific workflows, validation logic, filing processes, customer support, and XatBot AI.
This allows users to access filing guidance, understand validation issues, and navigate relevant requirements within the same platform used to prepare and manage their Pillar Two obligations.
What comes next
The June 30 deadline closed the first major filing cycle, but it did not complete the work.
Tax teams are now managing authority feedback, corrections, amended returns, and resubmissions. At the same time, they are preparing for jurisdictions whose first major Pillar Two filing deadlines will fall in the next cycle.
Orbitax is continuing to expand its filing infrastructure to support amendment and resubmission workflows, strengthen jurisdiction-specific validations, and extend direct transmission capabilities where tax authorities make the necessary interfaces available.
The next filing season will be broader. More jurisdictions will introduce or mature their filing requirements, and multinational groups will need to move from initial implementation into a repeatable annual compliance process.
The lesson from the first season is clear: Pillar Two filing is no longer a future requirement or a calculation exercise. It is an operational global compliance process that requires tax expertise, coordinated workflows, and technology designed to support execution across jurisdictions.
To learn how the Orbitax Global Minimum Tax solution can support your next Pillar Two filing cycle, contact your Orbitax account manager or book a demonstration.
Interested to learn more?
If you would like to explore how Orbitax can support your Pillar Two compliance efforts, please contact us using the details below:
Jeroen van Asch
Global Head of Sales & Partnerships
+31 6 42213812