What's New in Pillar 2

The GloBE Information Return (GIR) XML export is now available for your first filing. A new readable preview lets you review the submitted content, navigate between jurisdictions, and use the export or print options.

The GIR XML report requires separate receiving-jurisdiction codes for the General Section, Summary, and Jurisdiction Section. In Group Data Collection, you can now define who receives the General Section. In Jurisdictional Data Collection, you can define which jurisdictions receive the Summary for each subgroup and the Jurisdiction Section for each jurisdiction. The preselected Receiving Country (GEN-3.2) remains mandatory and always receives the complete report. The Receiving Country field is now also shown in the Start Transmission dialog when GIR is selected.

In Jurisdictional Data Collection, the new Jurisdiction(s) with Taxing Rights section lets you list all jurisdictions that hold taxing rights for the selected country and, where applicable, capture Reportable Differences for cases in which jurisdictions calculate top-up tax differently. A new Add Jurisdiction with Taxing Rights button opens a detail view where you can enter the relevant data.

In Jurisdictional Data Collection, field DMT-0.2 lets you choose whether the QDMTT calculation is included in the Global Snapshot or taken from a Separate QDMTT Snapshot. When Separate QDMTT Snapshot is selected and finalized, the GIR XML file and its preview use the relevant QDMTT values from the marked snapshot. To review the QDMTT calculation data itself, open the corresponding QDMTT Snapshot. In the Global Snapshot detail view, the jurisdiction overview shows which QDMTT snapshots are included and which version they are based on. If a newer version exists or relevant differences were added afterward, a warning is shown so that you can create a new Global Snapshot before submission.

For German QDMTT, Entity Data Collection now includes a dedicated QDMTT Germany workspace under a new QDMTT menu for Constituent Entity Information. The master data required for German QDMTT is maintained in Jurisdictional Data Collection, which displays Germany-specific QDMTT fields whenever Germany is the selected jurisdiction. This also changes the German QDMTT Snapshot, which no longer includes all Group Data information and instead contains the specific German QDMTT fields from the jurisdictional data collection for Germany. The German QDMTT XML for Elster transmission is now available.

You can now submit GIR and QDMTT reports via the Tax Transfer Hub (TTH) from Pillar 2.

A new Income Inclusion tab is now available in Detail Results. Fields TA-4.1 to TA-5 and TA-7 have moved from C5 – Top-up Tax Allocation to the new tab, which also contains the IIR Offset and Additional Current Top-up Tax. In Overview Results, the Top-Up Tax Liability chart includes a TA-6 segment for any Additional Current Top-up Tax.

In Pillar 2, you can now report Deemed Distribution Tax (DDT) under Article 7.3. You can record whether the Deemed Distribution Tax election under Article 7.3.1 has been made and, for each fiscal year, capture the recapture mechanism: the fiscal year, total DDT paid or used, opening and closing balances of recapture accounts, and DDT paid or used in the reporting year and the three preceding years. When a constituent entity (CE) leaves the group, you can report the reduction to Adjusted Covered Taxes for prior years and the incremental top-up tax per Article 5.4.1.

Recording the DDT works as follows:

In Entity Data Collection | OECD-Standard, the new Deemed Distribution Tax workspace lets you enter the tax that would have been due if income subject to the Eligible Distribution Tax Regime had been distributed (Article 7.3.2(b)), and the taxes already paid on actual or deemed distributions (Article 7.3.3(a)). These values feed into the calculation.

In C4 – Jurisdictional Blending, a Deemed Distribution Tax section below Information displays the calculated DDT for the reporting year.

Pillar 2 now features GIR (GloBE Information Return), the standardized XML report under the OECD Pillar 2 rules. It contains the data that in-scope groups must submit to tax authorities, e.g. GloBE income, covered taxes, or constituent entity information. You can generate this report from your Pillar 2 data; Pillar 2 adds data to the required structure so your submission aligns with the OECD schema. The most important features are:

Pillar 2 now supports the submission of the GloBE Information Return (GIR) and Qualified Domestic Minimum Top-up Tax (QDMTT) reports to tax authorities. The process covers submission of new returns as well as corrections and deletions. You can now:

With the new Recapture mechanism in Pillar 2, you can adjust the Effective Tax Rate (ETR) and top-up tax calculations when there are material decreases in covered taxes for a prior year. This corrects previously overstated covered taxes that may have reduced the top-up tax liability.

For the entity data collection, a new Recapture workspace is available. You can enter and maintain all recapture data for the Deferred Tax Liability (DTL) in one place, i.e. annual amounts of DTLs subject to the recapture rule, aggregate recapture accounts for the reporting fiscal year, and aggregate recapture accounts for the prior fiscal year.

The values you enter are used in C2 – CE Calculations and in C4 – Jurisdictional Blending. You can review recapture data at constituent-entity level in C2 and at jurisdictional or subgroup level in C4. The data is available for the Pillar 2 XML report and supports the balance sheet comparison of Income Taxes, so you can meet the minimum requirements for reporting the DTL recapture mechanism.

Lucanet now provides comprehensive Safe Harbour exclusion capabilities to streamline your compliance with Pillar 2 regulations. Non-material entities qualifying for NMCE Safe Harbour can be excluded from full-scope calculations, i.e. workspaces C2 – CE Calculations, C4 – Jurisdictional Blending, and C5 – Top-up Tax Allocation by activating the check box EE-1 in the Entity Election and General Information workspace. Built-in validation warnings alert you when NMCE Safe Harbour is elected but not applicable, preventing potential compliance errors and improving workflow efficiency.

Pillar 2 now features a comprehensive calculation toolkit: The Income Inclusion Rule (IIR) and the Taxable Distribution method for investment entities are now fully integrated, covering all essential Pillar 2 use cases:

From preparation through allocation to the recapture of deferred taxes – the Transition Rules are now mapped out in significantly greater detail, making practical implementation easier for you:

The master data management of the Tax Administration module has been completely revised – your foundation for full XML reporting capability from mid-2026 onwards.