Finland updates minimum tax act to reflect latest Pillar Two guidance, implement Side-by-Side package

Irish Revenue has issued eBrief No. 063/26, revising Tax and Duty Manual guidance on the participation exemption under section 831B TCA 1997 for certain foreign dividends and distributions.

The German Ministry of Finance has released a draft bill to implement the Multilateral Competent Authority Agreement on the Exchange of GloBE Information Returns (GIR MCAA), enabling streamlined global minimum tax reporting for multinational enterprises.

New guidance clarifies eligibility, process, and documentation requirements for MAP assistance under Russia’s double taxation agreements.

The ATO  has released guidance on how Pillar 2 minimum tax rules apply to tax consolidated group restructures, covering the treatment of deferred tax assets and liabilities during transition years, asset transfer integrity rules, and the conditions governing ownership interest transfers and fair value elections.

Australia's Tax Office has opened public consultation on Draft Practical Compliance Guideline PCG 2026/D1, setting out its approach to determining risk-weighted assets attributable to Australian branches of foreign banks for thin capitalisation purposes, with comments due by 8 May 2026.

France's tax authority has released Form 2272-SD and accompanying guidance for reporting Pillar 2 top-up tax, covering the income inclusion rule, undertaxed profits rule, and qualified domestic minimum top-up tax — setting out allocation formulas, centralisation options, and mandatory e-filing requirements to ensure large multinationals meet the 15% minimum effective tax rate across their French operations.