Albania signs Multilateral Convention for the Implementation of the Pillar 2 Subject to Tax Rule
Albania became the 10th country to sign the STTR MLI, the OECD confirmed. The OECD announced that Albania signed the Multilateral Convention for the Implementation of the Pillar 2 Subject to Tax Rule (STTR MLI) on 23 September 2025. Albania is
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Kazakhstan: MOF updates CFC preferential tax jurisdictions list
Kazakhstan approved a 56-country CFC preferential tax list, effective from 1 January 2026. Kazakhstan’s Ministry of Finance (MOF) approved Order No. 492 of 12 September 2025, updating the list of countries and territories with preferential
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Germany signs multilateral GloBE information exchange agreement
Germany signed the GIR MCAA on 19 September 2025, joining 17 jurisdictions under Pillar 2 of the OECD/G20 framework. Germany signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) on 19 September
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Australia: ATO releases official form to revoke thin capitalisation test elections
The form enables eligible entities to revoke a previously made thin capitalisation test choice, including the group ratio or third-party debt tests. The Australian Taxation Office (ATO) released the official form for revoking thin capitalisation
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Czech Republic: President signs bill amending rules Pillar 2 rules, updates top-up tax deadlines
The President of the Czech Republic signed a bill amending the Act on Top-Up Taxes, aligning Pillar 2 filing and local tax deadlines with OECD timelines. The President of the Czech Republic, Petr Pavel, signed a bill amending the “Act on Top-Up
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Poland: MoF consults functioning of General Anti-Tax Avoidance clause under Administrative Tax Code
Interested parties can submit their opinions by 8 October 2025. Poland’s Ministry of Finance and Economy has initiated a public consultation to evaluate the General Anti-Tax Avoidance (GAAR) clause, which was introduced in 2016 under the
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South Africa: SARS issues update on Pillar 2 global minimum tax implementation
The implementation of the GloBE Model Rules in the GMT legislation enables South Africa to impose a multinational top-up tax at a rate of 15% on the excess profits of in-scope MNE Groups. The South African Revenue Service (SARS) has issued an
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Ukraine: STS clarifies CFC reporting penalties
Ukraine requires annual CFC reports, with penalties waived during martial law if filed within six months after it ends. Ukraine’s State Tax Service (STS) has clarified that, under the country’s controlled foreign company (CFC) rules, a
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Bahrain: NBR updates guidance on Domestic Minimum Top-Up Tax
The guidance clarifies scope, exclusions, and safe harbors. Bahrain’s National Bureau for Revenue (NBR) published an updated guidance on 12 August 2025 concerning the 15% Domestic Minimum Top-Up Tax (DMTT), effective from 1 January 2025. The
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Philippines introduces tax reforms targeting large-scale metallic mining activities
Republic Act No. 12253 takes effect on 20 September 2025, affecting large-scale metallic mining contractors 150 days later, with implementing rules to be issued within 90 days. The Philippines has published Republic Act No. 12253, an Act
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Nigeria gazettes tax reform acts, updates corporate and minimum effective tax rates
The Nigeria Tax Act 2025 and the Nigeria Tax Administration Act 2025, which will take effect on 1 January 2026, as well as the Nigeria Revenue Service (Establishment) Act 2025 and the Joint Revenue Board (Establishment) Act, which came into force on
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Thailand: Cabinet approves bill on Qualified Refundable Tax Credits in Pillar 2 framework
The Bill allows promoted companies to receive cash refunds for unused tax credits, which are treated as income for Pillar 2 purposes, ensuring no adverse effect on the effective tax rate. QRTCs cover investments in R&D, advanced skills,
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Uruguay: 2025–29 budget bill proposes new domestic minimum tax
Uruguay’s 2025–29 Budget Bill proposes a new domestic minimum tax for large multinational groups, effective 2027. Uruguay’s 2025–2029 Budget Bill, submitted on 31 August 2025, introduces a Pillar 2 Qualified Domestic Minimum Top-Up Tax
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Portugal approves registration form for Pillar 2 regime
Portugal issued Form 62 for the GMT regime, requiring filings from covered multinational and large domestic group entities with defined rules and deadlines. Portugal published Ordinance No. 290/2025/1 in the Official Gazette on 2 September 2025,
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Canada consults draft tax legislation, includes several previously announced measures including amendments to global minimum tax Act
The government invites all interested Canadians and stakeholders to provide feedback on these draft legislative proposals by emailing their comments to consultation-legislation@fin.gc.ca by 12 September 2025. Canada’s Department of Finance
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Chile: SII clarifies thin capitalisation exemption for financial entities
The tax administration clarified that to be exempt from thin capitalisation rules, an entity must engage solely in financial activities (with limited complementary activities), certain assets are excluded from the 90% threshold, and the commercial
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Germany publishes prescribed data set for Pillar Two GloBE information returns
Germany has issued the official XML data set and schema for filing minimum tax reports under Pillar Two from fiscal years starting after 30 December 2023. Germany’s Ministry of Finance has released the officially prescribed data set and schema
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OECD endorses Brazil’s additional CSLL under Pillar Two as a QDMTT
The OECD has recognised Brazil’s additional social contribution on net profits (CSLL) as a qualified domestic minimum top-up tax (QDMTT) meeting the safe harbour criteria. The OECD officially recognised Brazil’s additional social
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