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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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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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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Albania signs Multilateral Convention for the Implementation of the Pillar 2 Subject to Tax Rule
Albania became the 10th country to sign the STTR MLI, the OECD confirmed. The OECD announced that Albania signed the Multilateral Convention for the Implementation of the Pillar 2 Subject to Tax Rule (STTR MLI) on 23 September 2025. Albania is
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Germany signs multilateral GloBE information exchange agreement
Germany signed the GIR MCAA on 19 September 2025, joining 17 jurisdictions under Pillar 2 of the OECD/G20 framework. Germany signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) on 19 September
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Czech Republic: President signs bill amending rules Pillar 2 rules, updates top-up tax deadlines
The President of the Czech Republic signed a bill amending the Act on Top-Up Taxes, aligning Pillar 2 filing and local tax deadlines with OECD timelines. The President of the Czech Republic, Petr Pavel, signed a bill amending the “Act on Top-Up
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South Africa: SARS issues update on Pillar 2 global minimum tax implementation
The implementation of the GloBE Model Rules in the GMT legislation enables South Africa to impose a multinational top-up tax at a rate of 15% on the excess profits of in-scope MNE Groups. The South African Revenue Service (SARS) has issued an
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Bahrain: NBR updates guidance on Domestic Minimum Top-Up Tax
The guidance clarifies scope, exclusions, and safe harbors. Bahrain’s National Bureau for Revenue (NBR) published an updated guidance on 12 August 2025 concerning the 15% Domestic Minimum Top-Up Tax (DMTT), effective from 1 January 2025. The
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Thailand: Cabinet approves bill on Qualified Refundable Tax Credits in Pillar 2 framework
The Bill allows promoted companies to receive cash refunds for unused tax credits, which are treated as income for Pillar 2 purposes, ensuring no adverse effect on the effective tax rate. QRTCs cover investments in R&D, advanced skills,
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Uruguay: 2025–29 budget bill proposes new domestic minimum tax
Uruguay’s 2025–29 Budget Bill proposes a new domestic minimum tax for large multinational groups, effective 2027. Uruguay’s 2025–2029 Budget Bill, submitted on 31 August 2025, introduces a Pillar 2 Qualified Domestic Minimum Top-Up Tax
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