France proposes reduced surtax for large corporations in draft 2026 budget
For 2026, France intends to maintain the temporary corporate income surtax for large corporations at reduced rates, introduce a wealth tax, speed up the gradual abolition of the CVAE business tax, and revise its global minimum tax
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Singapore: Parliament reviews Finance (Income Tax) Bill 2025, includes new corporate tax relief measures
This legislation proposes numerous amendments to the Income Tax Act (ITA) and the Multinational Enterprise (Minimum Tax) Act (MMTA). Singapore's Parliament is reviewing the Finance (Income Taxes) Bill 2025, which had its first reading on 14
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Hungary: NAV Issues draft minimum top-up tax prepayment form
The draft 24GLBADO form is required for reporting and paying the QDMTT advance under the country’s implementation of Pillar 2 global minimum tax rules. Hungary's National Tax and Customs Administration (NAV) has introduced a draft version of
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Italy: MoF issues decree on Pillar 2 reporting, DAC9 compliance
Italy’s Ministry of Finance issued a decree for implementing Pillar 2 global minimum tax reporting obligations and the EU DAC9 Directive, aligned with OECD guidance. Italy’s Deputy Minister of Economy and Finance has signed a decree on 17
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Brazil: Federal Revenue Service amends QDMTT rules
Brazil’s Federal Revenue Service issued Normative Instruction 2282 on 3 October 2025, updating rules for the additional CSLL to align with OECD GloBE standards and confirming its status as a qualified domestic minimum top-up tax effective from
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UK updates Pillar 2 jurisdiction list
HMRC issued an updated Notice 2 expanding the list of territories and qualifying domestic top-up taxes recognised under the Multinational Top-up Tax Regulations 2025. The UK’s HM Revenue & Customs (HMRC) released a revised Notice 2
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Japan updates guidance on global minimum tax
NTA updated its guidance on global minimum tax rules, clarifying calculations and key definitions. Japan's National Tax Agency (NTA) released a revised version of its interpretative guidance on global minimum tax rules on 26 September
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Finland: Parliament reviews bill to enact DAC9
Finland’s Parliament is reviewing a bill to implement the EU’s DAC9 directive following a public consultation that ended on 26 September 2025. Finland’s Parliament is reviewing draft bill HE 142/2025 vp as of 10 October 2025, which aims
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France publishes guidance on Pillar 2 global minimum tax
France published BOI-IMG guidance regarding the implementation of the 15% global minimum tax for large domestic and multinational groups. The French tax authorities published the guidance (BOI-IMG), on 8 October 2025, regarding the implementation
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Denmark: Parliament reviews bill L 23 to implement EU DAC9
The bill proposes amendments to Danish tax laws to align with EU rules on Top-up tax reporting under DAC9, due by 31 December 2025. Denmark’s parliament is reviewing draft Bill L 23 on 8 October 2025, which aims to implement Council Directive
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Kazakhstan: MoF approves new CFC reporting, taxation forms for 2026
Ministry of Finance introduced new forms for reporting and taxing Controlled Foreign Companies, effective 1 January 2026. Kazakhstan’s Ministry of Finance issued Order No. 536 on 25 September 2025, approving new forms for the reporting and
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Brazil updates Contribution on Net Profit rules, aligns with QDMTT under Pillar 2
Brazil updated CSLL rules to align with Pillar 2 QDMTT, retroactively effective from 1 January 2025. Brazil’s Federal Revenue Service (RFB) has issued Normative Instruction No. 2.282 on 2 October 2025, amending Normative Instruction No. 2.228
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Israel consults draft law on domestic top-up minimum tax draft
Ministry of Finance initiated a public consultation on draft legislation introducing a domestic top-up minimum tax, set to apply from 1 January 2026 to Israeli-resident entities in multinational groups with global revenues of EUR 750 million or
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Germany: MOF revises guidance on cross-border tax dispute resolution
The key changes in the guidance are aimed at simplifying terminology, clarifying the interaction of dispute resolution mechanisms, and providing expanded guidance for joint applications from partnerships and corporate groups. Germany’s Ministry
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Turkey consults Pillar 2 global minimum tax implementation
The consultation is set to conclude on 27 October 2025. The Turkish Revenue Administration released a draft General Communiqué for public consultation, setting out the framework for implementing the Pillar 2 Global Minimum Tax (GMT) on 3 October
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Australia: ATO issues final ruling on thin capitalisation third-party debt rules
The TPDT, introduced by the 2024 Treasury Laws Amendment, replaces the arm's length debt test for general investors and financial entities with a simpler, more streamlined method. The Australian Taxation Office (ATO) has issued Taxation Ruling TR
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Hong Kong: IRD updates guidance on global minimum and top-up taxes
IRD updated rules on global minimum and top-up taxes, introducing the Pillar 2 Portal and new group registration requirements. Hong Kong’s Inland Revenue Department released an updated guidance on the global minimum tax and Hong Kong’s
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France: Tax Authorities flag common errors in Pillar 2 reporting
Tax authority warned of frequent errors in 2065-INT-SD filings, urging corrections to avoid penalties. The French tax administration has reported recurring mistakes in the filing of form 2065-INT-SD, which groups subject to country-by-country
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