Belgium consults Pillar Two IIR top-up tax returns for 2024–25
Belgium’s Federal Public Service (SPF) Finance has launched a public consultation on 17 March 2026 on draft top-up tax returns under the Pillar Two Income Inclusion Rule (IIR) for the 2024 and 2025 tax years, along with accompanying explanatory
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France issues guidance on treaty-based dividend withholding relief
France’s tax authority has issued guidance clarifying its taxation methods for dividends and similar income under international tax treaties, particularly focusing on treaty benefits for distributions to residents of countries with specific
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Poland gazettes DAC8 crypto-asset reporting, DAC9 Pillar Two top-up tax exchange directives
Poland has published the Act of 13 February 2026 amending the Act on the Exchange of Tax Information with Other Countries and certain related legislation in the Official Gazette on 17 March 2026, implementing the Council Directive (EU) 2023/2226 of
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Romania gazettes GloBE deferred tax accounting rules
Romania’s Ministry of Finance has published Order No. 203/2026 in the Official Gazette No. 196 on 13 March 2026, detailing how deferred tax is to be recorded in the accounting records of constituent entities subject to Law No. 431/2023, which
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Montenegro: Parliament adopts Pillar Two global minimum tax law
Montenegro’s parliament has adopted the Law on Global Minimum Corporate Income Tax, aligning the country’s tax framework with international standards under the Organisation for Economic Co-operation and Development (OECD) Pillar Two initiative.
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Kazakhstan approves country list for CFC exemption tied to corporate tax thresholds, treaty criteria
Kazakhstan's Minister of Finance has approved a comprehensive list of countries whose businesses qualify for double taxation treaty benefits based on their corporate tax rates. The approved countries must maintain a nominal corporate income tax
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Korea (Rep.) introduces transfer pricing reforms, Pillar Two rollout
Korea (Rep.) has published Presidential Decree No. 36128, partially amending the enforcement Decree of the International Tax Adjustment Act, in the Official Gazette on 27 February 2026. The Decree introduces sweeping updates to its international tax
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Greece: AADE issues guidance on Pillar Two top-up tax information return
Greece’s Independent Authority for Public Revenue (AADE) has issued new guidance, under Decision A. 1055 published on 12 March 2026, for reporting the entity responsible for submitting the Pillar Two Supplementary (Top-up) Tax Information
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Finland: Parliament enacts amendments to Pillar 2 rules to incorporate OECD, G20 guidance on advanced rulings
Finland’s parliament adopted the law proposals HE 196/2025 and HE 6/2026 on 11 March 2026, amending the Law on Minimum Tax by Large Groups (Pillar Two rules) to align with new international guidance and strengthen enforcement mechanisms. The
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South Africa: SARS opens eFiling global minimum tax registration
The South African Revenue Service (SARS) announced, on 16 March 2026, that registration for Global Minimum Tax is now open on the SARS eFiling system, as part of South Africa’s implementation of the Global Anti‑Base Erosion (GloBE)
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Malta: MTCA updates Pillar Two guidance following constituent entity filing exemption
Malta’s Tax and Customs Administration (MTCA) has issued Version 1.1 of its Guidance Note on the European Union Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups Regulations, following amendments
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Australia: ATO releases new Pillar Two guidance, organises information session in April
The Australian Taxation Office (ATO) released the updated guidance on Lodging, paying and other obligations for Pillar Two on 12 March 2026. The updated guidance on the Global and domestic minimum tax is designed to help multinational enterprise
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Taiwan: Northern Tax Bureau issues reminder on CFC rules
Taiwan’s Northern District National Taxation Bureau has issued a reminder to businesses regarding the Controlled Foreign Company (CFC) rules, which came into effect in 2023. The rules were introduced to prevent multinational enterprises from
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Poland enacts DAC8 crypto-asset reporting, DAC9 Pillar Two top-up tax exchange directives
Poland’s Ministry of Finance announced, on 11 March 2026, that the Act on the Exchange of Tax Information with Other Countries and Certain Other Acts has been signed into law. The legislation implements Council Directive (EU) 2023/2226 (DAC8) and
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Italy clarifies Swiss cantonal net wealth tax not creditable against CFC tax
The Italian tax authorities have issued Ruling Answer No. 70/2026, which addresses a specific tax query regarding whether a Swiss cantonal tax—the "Capital Tax"—can be deducted from the Italian taxes due under the Controlled Foreign Company
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Russia reminds organisations to file 2025 CFC notifications
Russia has reminded organisations that the deadline to submit notifications on controlled foreign companies (CFCs) for 2025 expires on 20 March 2026. This announcement was made on 4 March 2026. A CFC notification must be filed regardless of
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Japan: Cabinet introduces Side-by-Side Package in 2026 tax reform bill
Japan’s Cabinet has submitted the 2026 tax reform package to the National Diet of Japan, proposing amendments to global minimum tax rules, income tax provisions and consumption tax regulations. The bill updates Japan’s global minimum tax
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Netherlands issues tax guidance on permanent establishment requirements under Minimum Tax Act
The Dutch tax authorities issued guidance clarifying when a permanent establishment (PE) qualifies under the Minimum Tax Act 2024 (WMB 2024) on 26 February 2026, addressing critical questions about the Netherlands' implementation of the global
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