The European Commission has released detailed compliance guidance for multinational groups navigating Pillar Two across 14 EU Member States, but the manual reveals a fragmented landscape: whilst central filing of tax information is now possible under DAC9, groups cannot escape local compliance requirements, which differ materially depending on where their entities are established.

RF Report

The European Commission released a country-by-country compliance guide for multinationals navigating the EU’s new global minimum tax framework on 10 June 2026.

The “Manual for MNE Groups on Global Minimum Tax (Pillar Two) Compliance Obligations” covers Austria, Belgium, Croatia, Cyprus, Czech Republic, Finland, France, Germany, Greece, Ireland, Poland, Romania, Slovenia and Sweden, and stems from the SG REFORM Technical Support Instrument project aimed at building Member State capacity to implement Directive (EU) 2022/2523.

The manual is based on information available to 1 May 2026 and is not official EU guidance; domestic updates remain critical for compliance.

All 14 jurisdictions have transposed the Pillar Two Directive into domestic law, but implementation varies significantly. The manual highlights that groups with multiple entities in a single Member State face divergent compliance routes: some jurisdictions enforce a designated or liable entity model, whilst others permit optional appointments, apply local allocation rules, or require entity-by-entity filing. These structural differences mean groups cannot adopt a one-size-fits-all approach across borders.

Central filing does not eliminate local obligations

The EU’s DAC9 framework allows groups to submit a single Pillar Two information return centrally and route it between tax administrations. Member States were required to implement DAC9 by 31 December 2025; tax authorities must exchange the information by 31 December 2026, and the first Pillar Two top-up tax information returns are expected by 30 June 2026.

However, DAC9 addresses only the information return—analogous to the OECD’s GloBE Information Return—not every domestic compliance requirement. Groups filing centrally must still manage local registration, notifications to appointing a designated entity, payment obligations, XML schema validation, and reasonable care documentation. For groups filing outside the EU, verification of active GIR MCAA bilateral exchange relationships for the relevant year remains essential; the OECD publishes an updated registry of operational GloBE exchanges.

Pillar Two compliance deadline reference matrix

Country Registration / notification TIR / GIR / TTIR filing Local top-up tax return Payment / prepayment
Austria No group registration 15/18 months 31 December of second year after FY Due by return filing deadline
Belgium Within 30 days from start of first in-scope FY 15/18 months (extended first deadline) DTT: 11 months; IIR/UTPR: 15/18 months; first deadlines extended to 30 September 2026 Assessment notice; prepayment system applies
Croatia No group registration 15/18 months DTT: 15/18 months; IIR/UTPR: 30 days after TIR 30 days after return filing deadline
Cyprus Annual notification before TIR deadline 15/18 months 30 days after TTIR deadline 30 days after TTIR deadline
Czech Republic No group registration 15/18 months 22 months Due by return filing deadline
Finland No group registration 15/18 months 15/18 months Assessment notice
France Annual notification with CIT return 15/18 months 15/18 months Due upon return filing
Germany Group-head notification to BZSt (no formal registration) 15/18 months; not before 30 June 2026 Aligned with GloBE information return One month after top-up tax return filing
Greece No group registration 15/18 months One month after TIR One month after top-up tax return filing
Ireland One-time registration, tied to first in-scope year 15/18 months 15/18 months Due on specified return date
Poland No group registration 15/18 months 18/21 months 18/21 months
Romania No formal registration 15/18 months 15/18 months 15/18 months
Slovenia No group registration 15/18 months DTT: 15/18 months; IIR/UTPR: 30 days after TIR 30 days after return filing deadline
Sweden Within 15 months after first in-scope FY-end 15/18 months One month after TIR 90 days after final assessment notice; IIR/UTPR preliminary payment possible

Key: DTT = Domestic Top-up Tax; IIR = Income Inclusion Rule; UTPR = Undertaxed Profits Rule; TIR = Top-up Tax Information Return; TTIR = Top-up Tax Information Return; FY = Fiscal Year; CIT = Corporate Income Tax; BZSt = German Federal Tax Office