Pillar Two update: More filing challenges

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Phil Ramstetter, a Chicago-based International Tax Partner at PwC and Pillar Two subject matter specialist. Phil previously served as a tax policy consultant at Business at OECD (BIAC). Doug and Phil discuss the evolving Pillar Two landscape, including the OECD’s 2026 guidance, BIAC’s role in shaping workable rules, and the side-by-side and UPE safe harbors. They examine UTPR allocation and GIR validation problems arising from differences in domestic laws, alongside new guidance on explicitly conditional taxes and mismatched QDMTT fiscal years. The conversation also covers revised GIR and XML reporting, continuing QDMTT compliance for US-parented groups, upcoming guidance on related benefits and integrity measures, and why greater taxpayer input, prospective rulemaking, and filing standardization are essential to meaningful simplification.