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
See MoreMontenegro: Parliament approves Pillar Two global minimum tax
The Parliament of Montenegro approved the Global Minimum Corporate Tax Law on 27 February 2026, introducing a 15% minimum effective tax rate for large multinational groups operating in the jurisdiction. The legislation aligns Montenegro’s tax
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Sweden consults R&D tax incentives under Pillar Two, aligns with Side-by-Side Package
Sweden’s Ministry of Finance (MoF) has launched a public consultation under Memorandum No. Fi2026/00105 on proposed tax incentives for research and development (R&D) personnel costs and its interaction with OECD Pillar Two rules on 24 February
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UK: HMRC updates guidance on qualified IIR, QDMTT jurisdictions
UK’s Tax Authority, HM Revenue & Customs (HMRC) has issued an updated notice specifying jurisdictions with a qualified income inclusion rule (IIR) and/or a qualifying domestic top-up tax (QDMTT) that meets safe harbour standards. The
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CJEU rules Belgium non-compliant for excluding foreign tax credits under ADAT CFC framework
The Court of Justice of the European Union (CJEU) delivered a judgment on 26 February 2026, examining how Belgium has transposed the Controlled Foreign Company (CFC) rules under the Anti-Tax Avoidance Directive (ATAD). The case centred on whether
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