Switzerland: FTA clarifies Pillar Two Side-by-Side Package application
The Swiss Federal Tax Administration (FTA) on 7 April 2026 released official statements clarifying how Switzerland will apply the Pillar Two Side-by-Side Package and related administrative guidance on Article 9.1 of the Global Anti-Base Erosion
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Hungary releases technical specifications for DAC9 global minimum tax reporting
Hungary's National Tax and Customs Administration (NAV) has published the technical API specifications for DAC9 reporting on 25 March 2026. The affected taxpayers must submit their first GloBE Information Return (GIR) by 30 June 2026, as mandated
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Belgium extends Pillar Two tax filing deadlines
Belgium’s Federal Public Service (SPF) Finance has announced, on 3 April 2026, the extension of the filing deadlines for Pillar Two minimum tax declarations. The extensions apply to both the Qualified Domestic Minimum Top-up Tax (QDMTT) and
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India: CBDT grants GAAR (general anti-avoidance rule) relief for pre-April 2017 investments
India’s Central Board of Direct Taxes (CBDT) has released Notification 54/2026 and Notification 55/2026, introducing amendments to the Income Tax Rules, 1962 and 2026, concerning the application of the general anti-avoidance rule (GAAR) on income
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Italy introduces digital filing system for Pillar Two minimum tax notification, return
The Italian Revenue Agency has introduced new software to facilitate compliance with the Pillar Two global minimum tax framework, marking a significant step in implementing the OECD's international tax reforms. Companies subject to the
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Canada: 2025 Budget Implementation Act overhauls transfer pricing rules, scraps digital services taxÂ
Canada’s Bill C-15, or the Budget 2025 Implementation Act, No. 1, which received Royal Assent on 26 March 2026, introduces a major overhaul of Canada's transfer pricing regime, repeals the Digital Services Tax, and enacts a wide array of business
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Sweden gazettes Pillar Two amendments allowing centralised top-up tax responsibility
Sweden has published amendments to its Top-up Tax Act (2023:875) in the Official Gazette (SFS 2026:305) on 31 March 2026, allowing a single resident group entity to assume responsibility for a group’s supplementary top-up tax. Key details of
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Japan enacts 2026 tax reform, implements side-by-side safe harbour
Japan’s National Diet approved the 2026 tax reform legislation on 31 March 2026, which has been published in the Official Gazette. The measures reflect proposals released in December 2025 and January 2026, covering income, corporate,
See MoreItaly issues rules for optional substitute tax as alternative to CFC regime
Italy’s tax authorities have issued updated guidance, under Protocol No. 106520 of 31 March 2026, which details the voluntary tax option that allows Italian controlling entities to pay a flat 15% substitute tax on the net accounting profits of
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Australia: ATO issues guidance on revising global, domestic minimum tax assessments, GIR
The Australian Taxation Office (ATO) issued new guidance on Amending a global and domestic minimum tax assessment and Globe Information Return (GIR) on 31 March 2026. Check if an amendment is needed To correct mistakes in relation to the
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Greece consults DAC9 Top-up Tax Information Return, DAC8 crypto-asset reporting
The Greek Ministry of Finance (MoF) has launched a public consultation on a draft bill aimed at modernising administrative cooperation in taxation and implementing recent European Union directives on 29 March 2026, after which it is expected to
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Netherlands introduces ‘Freedom Contribution’ in 2026 Spring Memorandum
The Dutch Government has published the Spring Memorandum 2026, updating the 2026 budget and outlining forward-looking plans, including a range of tax measures. Key provisions reflect those agreed in the Coalition Agreement for 2026–2030, released
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Greece confirms UTPR, transitional CbCR safe harbours under Pillar Two enters into force
Greece’s Ministry of Finance (MoF) has confirmed that the undertaxed profits rule (UTPR) and the transitional country-by-country reporting (CbCR) safe harbours under Pillar Two, as established in the Minimum Taxation Directive (2022/2523),
See MoreSweden implements Side-by-Side, UPE safe harbours under global minimum tax
Sweden's Ministry of Finance (MoF) has proposed amendments to the Additional Tax Act (2023:875) to implement the side-by-side arrangement agreed by the OECD Inclusive Framework on 5 January 2026. The changes aim to align Swedish law with OECD/G20
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Czech Republic updates non-cooperative jurisdictions list for CFC rules, adds Vietnam
The Czech Republic has published Financial Bulletin No. 5/2026 on 20 March 2026, which includes an updated list of jurisdictions classified as non-cooperative for tax purposes, aligning its domestic rules with the latest decisions of the Council of
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US: IRS issues guidance on elections for business interest limitation relief, bonus depreciation exemption
The US Internal Revenue Service (IRS) issued Revenue Procedure 2026-17, which provides guidance on withdrawing elections for excepted trades or businesses under §163(j)(7) and making late elections to opt out of bonus depreciation under
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Germany: MoF publishes draft bill to implement GloBE information exchange
The German Ministry of Finance (MOF) on 20 March 2026 published a draft bill to implement the Multilateral Competent Authority Agreement on the Exchange of Global Anti-Base Erosion (GloBE) Information Returns (GIR MCAA), which Germany signed on 19
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Australia: ATO issues guidance on Pillar Two rules for tax consolidated group restructures, transition rules
The Australian Taxation Office has released guidance on tax consolidated group restructures and transition rules, outlining how Australia’s Pillar 2 minimum tax rules apply to acquisitions, restructures, and other ownership or asset transfers
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