Austria consults Tax Amendment Act 2026 with Pillar Two safe harbours
Austria’s Federal Ministry of Finance announced a consultation on 22 October 2026 on the draft Tax Amendment Act 2026 (Abgabenänderungsgesetz 2026, or AbgÄG 2026) on 21 October 2026. The bill would amend 22 federal laws, with the Pillar Two
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Hong Kong opens Pillar Two portal for top-up tax returns, mandates e-filing
Hong Kong’s Inland Revenue Department (IRD) has launched new functions on its Pillar Two Portal from 26 October 2026. A Part 4AA entity of an in-scope MNE group can now file a top-up tax return and view and download notices of top-up tax
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Switzerland: Federal Council amends minimum tax rules to delay OECD guidance
Switzerland’s Federal Council adopted the amendment at its meeting in Bern on 21 October 2026. It implements two parliamentary motions with identical wording, which called for the guidance to apply in Switzerland one year later than the date
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France authorises Pillar Two GloBE information exchange agreement
France published Law No. 2026-963 of 19 October 2026 in Issue No. 245 of the Journal officiel de la République française on 20 October 2026, authorising approval of the Multilateral Competent Authority Agreement on the Exchange of GloBE
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Belgium: Parliament approves DAC9 law on Pillar Two tax information exchange
The Belgian Chamber of Representatives approved a law implementing Council Directive (EU) 2025/872 of 14 April 2025 (DAC9) on 22 October 2026. The directive establishes rules for the automatic exchange of information on Top-up Tax Information
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Ukraine proposes ATAD-aligned anti-avoidance rules to combat aggressive tax planning
Ukraine’s government has approved Draft Law No. 16150 prepared by the Ministry of Finance to implement provisions of the Anti-Tax Avoidance Directive (2016/1164) (ATAD) aimed at combating aggressive tax planning. Draft Law No. 16150 was
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Hungary: NAV publishes 2025 global minimum tax return form
Hungary’s tax and customs administration (NAV) published Form 25GLBADO on the ONYA platform on 21 October 2026 for the declaration and payment of the additional taxes that secure the global minimum tax level, along with the recognised domestic
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Uruguay issues decree introducing domestic minimum top-up tax
Uruguay’s government’s Executive Branch issued a decree on 16 October 2026, yet to be published in the Official Gazette, establishing the domestic minimum top-up tax (DMTT) (Impuesto Mínimo Complementario Doméstico or IMCD) regulations,
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South Africa proposes SEZ transfer pricing reforms, corporate tax changes in Medium-Term Budget Policy
South Africa’s National Treasury has delivered the Medium-Term Budget Policy Statement (MTBPS) to Parliament on 21 October 2026. This package comprises three key amendment bills designed to implement the government's tax policy, monetary
See MoreFrance ratifies OECD GloBE information exchange agreement under Pillar Two
France has ratified the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) under Pillar Two of the OECD/G20 Inclusive Framework’s Two-Pillar Solution, the French authorities confirmed. The approval was
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Bulgaria amends tax procedure code to implement DAC8 and DAC9, revise transfer pricing rules
Bulgaria's government has promulgated the Law amending the Tax and Social Security Procedure Code (TSSPC), published in State Gazette No. 85 on 15 September 2026 under Decree No. 302. The Law transposes Council Directive (EU) 2023/2226 (DAC8) and
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OECD releases Version 2.0 of GIR XML Schema
The OECD published an updated user guide and XML schema for the Pillar Two GloBE Information Return (GIR) on 20 October 2026. Version 2.0 reflects recent changes to the GIR made after the adoption of the Side-by-Side Package. It also includes
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Uruguay updates dividend withholding tax rules
Uruguay has published Decree No. 427/026 of 1 October 2026, introducing rules for withholding tax on dividends and profits under Budget Law No. 20.446 of 16 December 2025. The decree amends Decree No. 149/007 of 26 April 2007, which regulates the
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Ireland’s Finance Bill 2026 updates Pillar Two rules, expands tax reliefs
Ireland’s Department of Finance announced yesterday, 19 October 2026, the publication of the Finance (No. 2) Bill 2026 and its accompanying Explanatory Memorandum to implement Budget 2027. The Bill includes changes to corporate and personal
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IMF: Re-thinking taxation for the AI era
On 14 October 2026, at the IMF annual meetings, a forum discussion looked at Rethinking taxation for the AI era. The panel consisted of Adrian Brown, the Founder and CEO at Windfall Trust; Ioana Marinescu, Professor at the University of Pennsylvania
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Sweden submits Pillar Two bill with new safe harbours to Parliament
The Swedish government's legislative proposal (Proposition 2026/27:4), submitted to the Swedish Parliament (Riksdag) on 13 October 2026, incorporates the OECD/G20 Inclusive Framework's Pillar Two administrative guidance issued between June 2024 and
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France tables Pillar Two safe harbours, CbC reporting relief
The French government tabled Amendment I-3734 to the 2027 Finance Bill (Projet de loi de finances pour 2027, No. 3210) on 10 October 2026, introducing significant updates to France’s Pillar Two global minimum tax framework. The proposal
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Cyprus: House of Representatives considers Pillar Two amendments to introduce recognised QDMTT
The Cyprus House of Representatives is considering the Ensuring a Global Minimum Level of Taxation of Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union (Amendment) Law of 2026, which was introduced during a plenary session
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