Pillar Two at One Year: Early Lessons from European Implementation

Twelve months into Pillar Two implementation across the European Union, a consistent picture is emerging: the framework is robust in principle, but punishing in operational detail.

Our members, working across twelve EU jurisdictions, have observed three recurring pressure points — the transitional safe harbour cliff, the interaction between QDMTT and domestic group relief regimes, and the documentation burden on mid-market groups caught by the €750m threshold.

This note summarises the Council's consolidated view as of Q1 2026.