Australia: ATO issues final guidance on global and domestic minimum tax filing requirements
The Australian Taxation Office (ATO) has released Practical Compliance Guideline (PCG) 2025/4, Global and domestic minimum tax lodgment obligations - transitional approach, on transitional approaches for global and domestic minimum tax lodgment
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Taiwan: Tax Bureau clarifies CFC investment income deductions
Taiwan’s National Taxation Bureau, under the Ministry of Finance, has clarified rules on the calculation of Controlled Foreign Company (CFC) investment income for profit-seeking enterprises, emphasising that accumulated losses recorded in a
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Netherlands: Lower House approves amendments to minimum tax law, DAC9 implementation bill
The Netherlands' lower house of the parliament has adopted amendments to the Minimum Tax Act and an implementation bill for DAC9 on 27 November 2025. This bill is part of the 2026 Tax Plan package. It ensures that the Netherlands complies with
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Australia: ATO issues guidance on Pillar 2 filing obligations
The Australian Taxation Office (ATO) issued a guideline outlining its transitional approach to penalties and expectations for the four new Pillar 2 filing obligations on 26 November 2025, offering tailored guidance and certainty for MNEs during the
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Finland: Tax Administration updates Pillar 2 guidance on profit, tax allocation in complex group structures
Finland’s Tax Administration has issued an updated version of its guidance on the Law on Minimum Tax by Large Groups (Laki suurten konsernien vähimmäisverosta), providing fresh clarification on how profits, losses and taxes should be allocated
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France: National Assembly rejects first part of 2026 Finance Bill
France’s National Assembly rejected the revenue (tax) section of the 2026 Finance Bill on 22 November 2025. A general vote held the previous day resulted in the Bill being rejected at its first reading after several weeks of public debate, with
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Slovak Republic: MoF issues updated model tax return for Pillar 2 supplementary domestic top-up tax
The Slovak Republic’s Ministry of Finance has issued Notification No. MF/15676/2025-724, introducing a model tax return form for the additional (supplementary) domestic top-up tax, in accordance with the Pillar 2 QDMTT framework. The new
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Belgium: Scholars assist CJEU in reviewing Pillar 2 UTPR’s compliance with EU legal standards
A group of law professors filed an amicus curiae brief on 19 November 2025 with the Court of Justice of the European Union (CJEU) concerning a question referred by the Belgian Constitutional Court on whether the Pillar 2 UTPR is compatible with EU
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Hungary: Parliament adopts revised global minimum tax, reporting regulations
Hungary’s parliament approved two bills (T/12802/7 and T/12801/12) on 18 November 2025 that introduce significant updates to the country's tax framework and reporting obligations. Among the key changes, the legislation revises Hungary’s
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Bolivia: Chamber of Deputies considers 2026 state budget proposal
Bolivia’s Executive Branch has submitted the 2026 General Budget Bill to the Chamber of Deputies on 31 October 2025, outlining a series of targeted tax incentives to reduce the cost of public debt operations conducted in foreign capital
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Sweden: MoF proposes automatic exchange of top-up tax information under DAC9
The Swedish Ministry of Finance (MoF) submitted a proposal to the Legislative Council, on 13 November 2025, to introduce new rules for the automatic exchange of Top-up Tax information. The changes align Sweden’s framework with Council Directive
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EU Parliament endorses BEFIT corporate tax framework
The European Parliament has approved Legislative Resolution No. P10_TA(2025)0268 on the Business in Europe Framework for Income Taxation (BEFIT) on 13 November 2025. The resolution introduces a unified framework for corporate taxation across the
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Czech Republic: Supreme Administrative Court issues ruling on limits of transfer pricing rules
The Supreme Administrative Court (SAC) of the Czech Republic has issued a ruling on 12 November 2025, concerning a tax dispute involving the company Astemo Czech, s. r. o., and the Appellate Financial Directorate. The ruling includes informal
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Belgium extends Pillar 2 supplementary tax return deadline
Belgium’s Federal Public Service (SPF) Finance has announced, on 17 November 2025, an extension to the filing deadline for the annual supplementary national tax return. The law of 19 December 2023 (concerning the introduction of a minimum tax
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Estonia calls for Pillar 2 tax flexibility for small EU economies
Estonia announced a call for flexibility in implementing the Pillar 2 global minimum tax during a recent EU finance ministers’ meeting on 13 November 2025, the Ministry of Finance said. The country is among five EU member states that have
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Germany: Bundestag approves Pillar 2 amendments
Germany’s lower house of parliament (Bundestag) approved the second revised draft of a law amending domestic Pillar 2 rules and related measures on 13 November 2025. The legislation, formally titled “Law to Amend the Minimum Tax Act and
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Romania: ANAF consults Globe Information Return (GIR), notification
Romania’s tax authorities (ANAF) have launched a public consultation on a draft order regarding the approval of the format and content of the forms for the GloBE Information Return (GIR) and the Notification of the obligation to submit the GIR,
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Italy gazettes decree on global minimum tax return, payments
Italy’s government has published the Decree of 7 November 2025 from the Ministry of Finance in the Official Gazette on 10 November 2025. The Decree of 7 November 2025 establishes the filing and payment requirements for the global minimum tax,
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