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May 15, 2026

Article 23 Bis (5) empowers the Council of Ministers to issue detailed decisions regarding the practical application of the global and domestic minimum tax regime. These decisions will specifically cover registration for IIR and QDMTT, the filing of the GloBE Information Return, and the notification of filing identities and jurisdictions. It also mandates specific returns for Top-up Taxes under both the IIR and domestic rules. Effective from 1 January 2025, this article ensures that the administrative specifics of Pillar Two are handled through high-level executive decisions, allowing for the flexibility needed to manage complex international reporting requirements.

SECTION 7 BIS: GLOBAL AND DOMESTIC MINIMUM TAX

Article 23 Bis (5)

The Council of Ministers shall issue a decision on the controls for applying the provisions of this Chapter, which shall include in particular the following:

Registration for the purposes of applying the Income Inclusion Rule and the Domestic Minimum Top-up Tax.
The GloBE Information Return provided for in Article 8.1.1 of the GloBE Model Rules.
The notification of the identity of the entity filing the GloBE Information Return and the jurisdiction in which it is located, as provided for in Article 8.1.3 of the GloBE Model Rules.
The return for the Top-up Tax arising from the application of the Income Inclusion Rule.
The return for the Top-up Tax arising from the application of the Domestic Minimum Top-up Tax.