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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Australia: ATO issues final compliance guideline on restructures and updated thin capitalisation rules
This guideline outlines ATO’s practical compliance approach for restructures undertaken in response to the new thin capitalisation and debt deduction creation rules (DDCR). The Australian Taxation Office (ATO) has published the final
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Ireland: Irish Revenue updates Pillar Two guidance
The updated guidance outlines Pillar Two registration, filing, and top-up tax requirements for MNEs. Irish Revenue published updated guidance on Pillar Two requirements on 14 August 2025, covering an overview of Pillar Two, registration
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Sweden: Ministry of Finance proposes amendments to global minimum tax rules
The draft legislation aligns Sweden’s Top-up Tax Act with new OECD guidance and EU rules on global minimum taxation. Sweden’s Ministry of Finance published draft legislation on 14 August 2025 to amend Act (2023:875) on top-up tax for
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India introduces Pillar Two disclosure requirements under national accounting standard
India has amended Ind AS 12 to align with International Accounting Standard 12 and introduce new disclosure requirements for the OECD’s Pillar Two global minimum tax. India’s Ministry of Corporate Affairs has issued the Companies (Indian
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Chile clarifies indirect foreign tax credit treatment for CFCs
Ruling No. 1500-2025 confirms that the indirect foreign tax credit applies only if a treaty or information exchange agreement exists and the CFC owns at least 10% of the subsidiary. Chile’s tax administration (SII) issued Ruling No. 1500-2025
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Czech Republic: Senate approves updated deadlines for Pillar Two tax reporting
The Senate amended the Act on top-up taxes, extending first-time filing deadlines for the top-up tax information return and top-up tax return. The Czech Senate has approved an amendment to the Act on top-up taxes, extending the deadlines for the
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Taiwan: MoF clarifies direct and indirect holdings count in CFC rules
The finance ministry confirms both direct and indirect related-party ownership count when determining CFC status in low-tax jurisdictions. Taiwan’s Ministry of Finance has released a statement on 31 July 2025 clarifying that in assessing
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Switzerland clarifies top-up tax treatment of residual tax on distributions
Switzerland confirms treatment of residual tax on distributions for top-up tax calculations effective from 1 January 2024. The Swiss Federal Tax Administration released Communication-026-E-2025-e on 24 July 2025, clarifying the treatment of
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Italy implements emergency tax revisions on CFC, hybrid mismatch penalty rules
Urgent tax measures include revising the domestic CFC rules, tax loss carry-forward provisions, and the penalty protection regime for hybrid mismatch assessments. Italy’s parliament converted Law Decree No. 84 of 17 June 2025 into law with
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Taiwan: MOF tightens CFC loss submission rules
The finance ministry mandated that CFC losses are deductible only if audited statements or equivalent proof are filed by the tax deadline (plus a one-time six-month extension); otherwise, they're disallowed. Taiwan’s Ministry of Finance has
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Panama withdraws extended deadlines for tax treaty claim corrections
The new resolution only allows a 10-day extension, with the possibility of extending it up to 30 days. Panama published Resolution No. 201-5822 on 16 July 2025, in Official Gazette No. 30323, repealing Resolution No. 201-2232 of 16 March
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