Preparing for the Second Pillar Two Filing Season

The first Pillar Two filing season established what compliance with the GloBE Rules requires in practice. The second season will test whether that process can be repeated within a shorter filing window, in the final fiscal year to which the GloBE Rules apply in their present form.

For most groups, the FY2025 GloBE Information Return is not a more demanding return than that filed for FY2024. It is substantially the same return, prepared to a deadline three months earlier, with an additional charging provision in effect and with less administrative tolerance surrounding it.

What the First Season Showed

Orbitax analyzed more than 1,700 Pillar Two filings across 34 jurisdictions between November 2025 and June 2026. Two findings from The First Pillar Two Filing Report matter for what comes next.

More than 60% of filing activity was notifications and self-assessment returns rather than GIR filings. The GIR drew most of the attention, but the surrounding obligations produced most of the work.

Nearly one-third of activity landed in the final week before the deadline. Completed calculations did not mean completed filings. Local formats, reviews, validation checks, and portal submission still stood in the way.

Both patterns are likely to be more pronounced in FY2025, because the filing window itself is shorter.

The shape of the change

Two matters in the table account for most of the practical effect. The data model applicable to FY2025 is unchanged, so the mapping and calculation infrastructure developed for FY2024 remains applicable. The filing calendar, by contrast, has moved.

The filing calendar and Transition Year classification

Article 8.1.6 of the GloBE Model Rules requires the GIR and the accompanying notification to be filed no later than 15 months after the last day of the reporting fiscal year. Article 9.4.1 extends that period to 18 months where the reporting fiscal year is the Transition Year.

The Transition Year is defined by reference to a jurisdiction, being the first fiscal year in which the MNE Group comes within the scope of the GloBE Rules in respect of that jurisdiction. For the purposes of the GIR due date, however, several jurisdictions have taken the position that the additional three months is available only for the earliest Transition Year of the MNE Group. A group that was already within scope in FY2024 therefore should have a March due date for FY2025, notwithstanding that a jurisdiction in which it operates may be implementing the rules for the first time in that year.

Groups already within scope for FY2024

The FY2025 GIR is due on 31 March 2027 for a 31 December year end. The presence of a constituent entity in a jurisdiction implementing from 2025, such as Hong Kong, Singapore, Bahrain or Qatar, does not of itself restore the 18-month period.

Groups first within scope for FY2025

FY2025 is the Transition Year and the GIR is due on 30 June 2027. This applies principally to groups newly meeting the EUR 750 million consolidated revenue threshold in at least two of the four immediately preceding fiscal years, and to groups whose only in-scope jurisdictions are those implemented from 2025.

The Inclusive Framework has not issued guidance resolving whether the ‘transition year’ can apply at ‘jurisdiction level’, and the position should be confirmed in each jurisdiction concerned. Groups that filed the GIR for FY24 in any jurisdiction, may have only nine months before the next return falls due. A list of the jurisdictions in scope for FY2024 and FY2025 is set out in Annexure 1.

Illustration: a UK-based group, FY2024 against FY2025

Take a group with a 31 December year end, at least one UK constituent entity, and consolidated revenue above EUR 750 million. The UK’s Multinational Top-up Tax and Domestic Top-up Tax apply for accounting periods beginning on or after 31 December 2023; the UK’s undertaxed profits rule applies for accounting periods beginning on or after 31 December 2024.

Obligation	FY2024 (AP ended 31 Dec 2024)	FY2025 (AP ended 31 Dec 2025)	What moved
Register the filing member with HMRC	30 June 2025 — 6 months after the end of the first in-scope AP	Not repeated; one-time obligation while the filing member is unchanged	—
GIR, or Overseas Return Notification if the GIR is filed abroad	30 June 2026 — 18 months, first AP registered	31 March 2027 — 15 months	3 months earlier
UK Self Assessment return (or Below Threshold Notification), covering MTT and DTT	30 June 2026 — 18 months, first AP registered	31 March 2027 — 15 months	3 months earlier
Payment of MTT and DTT	By the return filing date	By the return filing date	Follows the return
UTPR content in the UK return	Not in charge	In charge — but the transitional UTPR Safe Harbour election remains available for a 12-month period commencing on or before 31 December 2025 where the UPE jurisdiction’s nominal rate is at least 20%	New line, often still a safe harbour position
HMRC transitional approach to central filing and late-filing penalties	Applies — the published approach covers cases where the GIR filing deadline falls no later than 31 December 2026	Does not apply — the FY2025 deadline of 31 March 2027 falls outside it	Concession withdrawn
Reliance on the exchanged GIR	HMRC will hold back local enforcement where it receives the centrally filed GIR within 6 months of the filing deadline	No equivalent published tolerance; under the GIR MCAA the standard exchange window after the transition year is 3 months	Tolerance replaced by a shorter statutory window

Nine months separate the two filings. The second filing carries an additional charging provision, and the published transitional approach to central filing no longer applies. The underlying obligations are the same: a GIR was required for FY2024, one is required for FY2025, and an Overseas Return Notification is still the route where the GIR is filed abroad. What falls away is the latitude the transitional approach gave on the timing of central filing and receipt of the exchanged GIR. No equivalent fallback has been published for FY2025, so the local obligation applies in full.

Local forms: the position is not yet settled

The obligation set is the same as in the previous cycle, and for many groups there is more of it:

• The GIR, filed centrally where central filing and exchange are available and locally where they are not.
• The GIR notification identifying the filing entity.
• Self-assessment returns, Domestic top-up tax returns and IIR returns, on local deadlines that frequently differ from the GIR deadline.
• UTPR returns, which for most groups carry content for the first time in respect of FY2025.
• Registration, which applies because a group is within scope rather than because tax is payable.

Whether the local forms issued for FY2024 will be reissued, amended or carried forward unchanged for FY2025 is not yet established, and it would be premature to draw a general conclusion in either direction. A small number of jurisdictions have issued distinct forms by reference to the year concerned. Belgium, for example, established separate Qualified Domestic Minimum Top-up Tax return forms for assessment years 2024 and 2025. Equally, only a limited number of authorities have confirmed that they have started accepting FY2025 submissions without any change from FY2024.

The position should therefore be treated as open and confirmed jurisdiction by jurisdiction as authorities publish. Orbitax is tracking each jurisdiction and will update its published position as each is established.

What has changed: new jurisdictions in scope and the UTPR

For groups entering scope in FY2025, the first obligations due are registrations and notifications rather than returns, and several of the relevant dates have already passed, including in Bahrain and Singapore . Qatar opened Pillar Two registration on its tax portal with a deadline of 2 November 2026. These obligations attach to being within scope, not to top-up tax being payable. The jurisdictions concerned are listed in Annexure 1.

The practical consequence for FY2025 is therefore:

• Form and process work is real now.
  The UTPR section exists on the return and must be completed, whether it carries an election or a number.
• Data work is real now too.
  Where the safe harbour is unavailable, a UPE jurisdiction below 20%, a fiscal year longer than 12 months, a group structure outside the election — the UTPR top-up tax has to be allocated between jurisdictions by reference to employee numbers and the net book value of tangible assets.

How Orbitax is approaching FY2025

Reader question	Where Orbitax stands
Which FY2025 forms exist, and when will they be usable?	As in FY2024, all FY2025 forms will form part of the Filing Manager library. Forms will fall into two categories: those that are unchanged from FY2024, which will remain available for preparation in respect of FY2025; and those that are amended or newly issued, which will be shown in the library with an effective date indication so that the correct form is selected. Orbitax is not in a position to state, at this stage, which forms will change. That determination is being made jurisdiction by jurisdiction as authorities publish, and the library will be updated as each position is confirmed.
Do I re-enter FY2024 data?	For the FY 2025 forms we are building a facility to transfer data from the FY 2024 forms into the FY 2025 forms. That is intended to cover cases wherein a user wants to move data from FY24 filings onto FY25 filings and not having to fill it again.
Is the UTPR handled?	Yes. Existing and new forms are being updated so that UTPR data is mapped and can be imported from the GMT Calculator or the GIR.
Which deadline applies to which entity?	Pillar Two Compliance grid accounts for the jurisdiction specific and form specific due dates generated dynamically based on the entity footprint in the scenario. GIR auto-exchange based on the GIR MCAA and DAC9 is already integrated with the Pillar 2 compliance grid and Due Date Tracker. Any change or clarification from the OECD impacting due date calendar will be swiftly integrated in the Orbitax platform.

First-season flexibility should not be assumed to repeat

The first cycle was managed with substantial administrative give, and most of it was tied to the FY2024 deadline specifically.

• Many jurisdictions limited the enforcement  of GIR errors in FY2024. A stricter approach should be expected from FY2025 onwards.
• The OECD’s May 2026 common understanding, under which signatory jurisdictions agreed to hold back enforcement of local GIR filing where the return was centrally filed in a listed jurisdiction, addressed the 2024 reporting fiscal year.
• A number of jurisdictions extended local filing deadlines. The Belgian extension of the QDMTT and IIR return deadlines to 30 September 2026, for instance, reached only fiscal years ending on or before 30 September 2025 and 31 May 2025 respectively; later periods revert to the statutory 11-month and 15-month rules.

The general direction is that tax authority systems and exchange infrastructure will be aligned and operational by the second cycle, and that conditions will tighten rather than relax. Planning FY2025 on the assumption that the latitude of the first season will be repeated is the most avoidable exposure in the cycle.

Bridging the FY24 and FY25 filings: What to do

1. Reset the calendar, not the model.

The data model applicable to FY2025 is unchanged; the deadline logic is not. The compliance calendar should be reviewed by jurisdiction against that determination. The position may also depend on where the group intends to file its GIR, which should be established as early as possible and discussed with advisers.

2. Prepare the calculations for FY2025.

The calculation worksheets are fully functional to take into account FY2025 provisions and hence the calculations under GMT can be finalized now.

3. Anchor on the earliest local deadline, not the GIR.

Belgium’s 11-month QDMTT return and the registration deadlines in the 2025-start jurisdictions come first followed by Vietnam and Turkey.

4. Decide the UTPR position per jurisdiction now.

Review and finalise UTPR calculation.

5. Close out FY2024 before FY2025 opens.

Confirm what was accepted, what generated errors, and how each jurisdiction takes an amendment. There are certain jurisdictions wherein the FY2024 due dates for certain forms have still not become due.

6. Confirm central filing before relying on it.

It depends on a ready filing jurisdiction and an activated exchange relationship with each destination. Where either is missing, the local obligation stands

7. Review the filing obligations and the filing method for each jurisdiction, and plan them now.

The obligations for each jurisdiction should be reviewed through the Pillar 2 Compliance Grid and Filing Manager, the filing method for each return established, and the filing instructions read in advance, so that any preparatory steps are identified in time. Those steps vary by jurisdiction and can take weeks to complete. Obtaining a Netherlands PKI certificate is one example, as are portal enrolment, agent authorisation and credentials for jurisdictions that file through an API. An internal filing plan built from that review is the single most effective protection against a late surprise.

The first season established that Pillar Two is a recurring compliance process rather than a one-time calculation. The second season tests whether that process holds on a shorter clock, in the last year before the rules change.

Annexure 1 – Jurisdictions in Scope, FY2024 and FY2025

1. In scope for FY2024 (38 jurisdictions)

Fiscal years beginning on or after 31 December 2023 or during 2024. Groups filing here have already passed their Transition Year, so FY2025 falls on the 15-month deadline.

Australia	France	Portugal
Austria	Germany	Romania
Barbados	Gibraltar	Slovakia
Belgium	Greece	Slovenia
Bahamas	Hungary	South Africa
BES Islands	Ireland	South Korea
Bulgaria	Italy	Spain
Canada	Japan	Sweden
Croatia	Liechtenstein	Switzerland
Cyprus	Luxembourg	Turkey
Czech Republic	Netherlands	United Kingdom
Denmark	North Macedonia	Vietnam
Finland	Norway

2. Added from FY2025 (19 jurisdictions)

Fiscal years beginning on or after 31 December 2024 or during 2025. FY2025 is the Transition Year for these jurisdictions, so the 18-month deadline applies.

Bahrain	Jersey	Qatar
Brazil	Kenya	Singapore
Curaçao (Draft)	Kuwait	Thailand
Guernsey	Malaysia	United Arab Emirates
Hong Kong	Mauritius	Uruguay
Indonesia	New Zealand
Isle of Man	Poland

3. Added from FY2026 onwards (3 jurisdictions)

Listed for planning only; these do not affect the FY2025 filing cycle.

Iceland (Draft)	Montenegro
Israel

4. Deferred application under Article 50 of the EU Directive (4 jurisdictions)

Estonia	Lithuania
Latvia	Malta

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