First Global Pillar Two Filings Show Massive Compliance
The first global filing season for the new 15% minimum tax, known as Pillar Two, has offered a concrete look at the operational demands placed on multinational tax departments.
Volume and Timing of Early Filings
Orbitax, an international tax platform, examined more than 1,700 filings submitted between November 1, 2025, and June 30, 2026 across 34 jurisdictions. The analysis shows that the GloBE Information Return (GIR) and related self‑assessment returns accounted for over 60% of the activity recorded on the platform.
Registrations, Qualified Domestic Minimum Top‑up Tax (QDMTT) returns, Income Inclusion Rule filings and additional GIRs added hundreds of separate obligations. The data also reveal a sharp surge in activity as the June 30 deadline approached: roughly 30% of the filings were created in the final seven days of the period.
In countries such as Canada, the United Kingdom, Switzerland, Germany, the Netherlands, Sweden and Austria, more than one‑third of the filings were generated during that last week. GIR notifications and self‑assessment returns made up almost two‑thirds of the filings produced in those final days, indicating that the rush was not limited to a single form type.
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Operational Challenges for Multinationals
Multinational groups faced a broadened set of tasks beyond the core return. Tax teams needed to map applicable requirements across their global footprints, coordinate multiple forms from a shared data set, meet differing local deadlines, and apply jurisdiction‑specific validation rules. The newly introduced authority systems added another layer of complexity.
“My main suggestion is to start well before the deadline, and to actually understand what you’re facing,” said Laszlo Icsu, senior director and head of tax for Europe, APAC and CEE at EPAM Systems. “I started on the data and the top‑up tax calculations about a year and a half before the filing itself, and that gave us enough lead time.” EPAM handled its 2024 Pillar Two filings in 27 countries, covering GIRs, QDMTT returns, zero‑liability returns and notifications.
The practical lesson emerging from the first season is that compliance must be designed for periods of peak activity. Tax departments require sufficient structure, visibility and processing capacity to keep control as multiple filings, reviews and authority interactions converge.
Canada and the United Kingdom together accounted for about 38% of the recorded filing activity. The five highest‑volume jurisdictions contributed just over half of the total, while nearly one‑third of activity occurred outside the ten most active jurisdictions. This pattern reveals a long tail of local requirements: even low‑volume jurisdictions demand dedicated analysis, form support, validation, deadline tracking and a proper submission process.
Behind each filing was a tax team wrestling with evolving local rules, data questions, internal reviews, validation errors and submission procedures. Coordination extended beyond tax staff to advisory firms, specialists, implementation teams, developers, support professionals and tax authorities.
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From a broader perspective, the early filing season signals that the global minimum tax is moving from a policy concept to a routine operational requirement. Companies that invest in integrated data platforms and clear workflow ownership are likely to avoid the last‑minute scramble that characterized much of the first cycle.
Next Steps After the Deadline
While the June 30 deadline closed the inaugural filing cycle, the work is not finished. Tax teams are now processing authority feedback, correcting errors, filing amended returns and preparing for the next round of deadlines in jurisdictions that will face their first major Pillar Two filing later.
Orbitax emphasizes that compliance demands more than technical tax knowledge. It also calls for coordinated workflows, clear ownership, adequate processing capacity and technology capable of supporting execution across multiple jurisdictions. The company’s analysis suggests that firms that internalize these capabilities will be better positioned for future filing seasons.
Preparedness will pay off.
