Brazil updates Contribution on Net Profit rules, aligns with QDMTT under Pillar 2
Brazil updated CSLL rules to align with Pillar 2 QDMTT, retroactively effective from 1 January 2025. Brazil’s Federal Revenue Service (RFB) has issued Normative Instruction No. 2.282 on 2 October 2025, amending Normative Instruction No. 2.228
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Israel consults draft law on domestic top-up minimum tax draft
Ministry of Finance initiated a public consultation on draft legislation introducing a domestic top-up minimum tax, set to apply from 1 January 2026 to Israeli-resident entities in multinational groups with global revenues of EUR 750 million or
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Germany: MOF revises guidance on cross-border tax dispute resolution
The key changes in the guidance are aimed at simplifying terminology, clarifying the interaction of dispute resolution mechanisms, and providing expanded guidance for joint applications from partnerships and corporate groups. Germany’s Ministry
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Turkey consults Pillar 2 global minimum tax implementation
The consultation is set to conclude on 27 October 2025. The Turkish Revenue Administration released a draft General Communiqué for public consultation, setting out the framework for implementing the Pillar 2 Global Minimum Tax (GMT) on 3 October
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Australia: ATO issues final ruling on thin capitalisation third-party debt rules
The TPDT, introduced by the 2024 Treasury Laws Amendment, replaces the arm's length debt test for general investors and financial entities with a simpler, more streamlined method. The Australian Taxation Office (ATO) has issued Taxation Ruling TR
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Hong Kong: IRD updates guidance on global minimum and top-up taxes
IRD updated rules on global minimum and top-up taxes, introducing the Pillar 2 Portal and new group registration requirements. Hong Kong’s Inland Revenue Department released an updated guidance on the global minimum tax and Hong Kong’s
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France: Tax Authorities flag common errors in Pillar 2 reporting
Tax authority warned of frequent errors in 2065-INT-SD filings, urging corrections to avoid penalties. The French tax administration has reported recurring mistakes in the filing of form 2065-INT-SD, which groups subject to country-by-country
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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
See MoreAustralia: 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 activitiesÂ
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 ratesÂ
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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