Pillar Two compliance playbook: Managing GIR, safe harbours and DMTT across the Middle East and APAC

As Pillar Two moves from policy to execution across the UAE, Qatar, Bahrain, Turkey, South Africa, the EU, and key APAC markets, the challenge for multinational groups is now operational. The focus has shifted to GIR reporting, safe harbour assessments, domestic minimum tax exposure, and building scalable compliance processes across jurisdictions with different timelines.

While the primary filing deadline for most Middle East-headquartered groups (FY2025) falls in June 2027, immediate requirements are already in effect. MNEs with subsidiaries in early-adopter jurisdictions—including the EU, UK, Australia, Turkey, and South Korea—must meet FY2024 obligations, with first filings due by June 30, 2026.

Organizations are responding with differing operating models—some adopting centralized “command and control” structures to ensure consistency, while others rely on decentralized, local‑first execution to address jurisdiction‑specific demands.

Safe Harbours continue to reduce compliance burden but now require active decision‑making, strong documentation, and careful navigation of the OECD’s extended “Side‑by‑Side” framework through 2027. GIR filings remain mandatory even where Safe Harbours apply, driving a shift away from spreadsheet‑heavy processes toward more scalable, phased compliance approaches.

This webinar will discuss how multinational groups can navigate the shift from policy to execution, with immediate focus on upcoming filing deadlines, operating model decisions, and safe harbour complexity. With early-adopter obligations already in effect and timelines accelerating, the session will provide practical guidance on how to achieve compliance readiness now while building a scalable, technology-enabled approach to support Pillar Two requirements across multiple jurisdictions.

Key themes

Pillar Two is now an execution challenge. Across the UAE, Qatar, Bahrain, Turkey, South Africa, the EU, and key APAC markets, the focus has shifted from interpreting rules to delivering accurate calculations, filings, governance, and meeting fragmented GIR and local deadlines.