South Africa: SARS expands GMT support for Pillar Two
The South African Revenue Service (SARS) enhanced its Global Minimum Tax (GMT) administration to support affected Multinational Enterprise (MNE) Groups in meeting their Pillar Two obligations under the Global Anti-Base Erosion (GloBE) Rules. The
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Bulgaria proposes convention update for Pillar Two taxes
The Bulgarian National Assembly on 1 September 2026 accepted for consideration Bill No. 52-602-02-16, which would amend the law ratifying the Convention on Mutual Administrative Assistance in Tax Matters, as amended by the 2010 protocol. The
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Bulgaria revises Pillar Two tax exchange framework
Bulgaria published Decree No. 304 in the State Gazette on 18 September 2026, promulgating the Law on the Supplement to the Law on the Ratification of the Convention on Mutual Administrative Assistance in Tax Matters. The amendment adds Pillar Two
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Albania deposits ratification instrument for Pillar Two STTR MLI
The OECD reported that Albania deposited its instrument of ratification for the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI) on 15 September 2026. Albania signed the STTR MLI on 23
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New Zealand: Inland Revenue updates Pillar Two GloBE registration, filing guidance
New Zealand Inland Revenue updated its guidance on 9 September 2026 on the application of the Pillar Two GloBE Rules to multinational enterprise (MNE) groups with a constituent entity in New Zealand. The GloBE rules apply to MNE groups with
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Netherlands unveils 2027 tax plan with corporate, VAT and PIT changes
The Dutch government presented the 2027 Budget, including the Tax Plan for 2027 (Belastingplan 2027), on 15 September 2026. Corporate adjustments From 2027, embedded currency hedging results on participation investments will no longer qualify
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US: Treasury welcomes revised Pillar Two GloBE Information Return (GIR)
The US Treasury has welcomed the OECD/G20 Inclusive Framework’s release of the revised GloBE Information Return (GIR) on 11 September 2026. The changes implement President Trump's directive to exempt American corporations from the international
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Belgium advances DAC9 framework for Pillar Two information exchange, penalty rules
Belgium’s Minister of Finance submitted a draft bill (Doc 56 1719/001) to the parliament on 10 September 2026 that establishes the operational and statutory framework for implementing Council Directive (EU) 2025/872 (DAC9) into Belgian domestic
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OECD updates Pillar Two rules with new legislative review, GIR and administrative guidance
The OECD has announced on 11 September 2026 that the OECD/G20 Inclusive Framework on BEPS has released a package on the Pillar Two Global Minimum Tax aimed at strengthening consistency and certainty for MNEs and jurisdictions. The package
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Uruguay replaces Pillar Two QDMTT exemption with compensation mechanism
Uruguay has issued Decree No. 206/026, replacing the exemption from the Pillar Two Qualified Domestic Minimum Top-Up Tax (QDMTT), known as the Impuesto Mínimo Complementario Doméstico (IMCD), for entities covered by certain fiscal stability
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Bahrain: NBR updates guidance on Domestic Minimum Top-up Tax returns
Bahrain’s National Bureau for Revenue (NBR) published an updated DMTT Return Filing Manual Version 1.1 on 6 September 2026, providing guidance for large Multinational Enterprise (MNE) groups on filing Domestic Minimum Top-up Tax (DMTT) returns,
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Sweden proposes direct Pillar Two top-up tax liability for joint ventures
Sweden’s government has submitted a proposal to the Council on Legislation to make Swedish joint ventures and their subsidiaries directly liable for Swedish national top-up tax under the Pillar Two rules. The legislative amendments, published
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Philippines: DoF consults on ProGRESS tax reform bill incorporating global minimum tax
The Philippines Department of Finance (DoF) launched consultations on the ProGRESS Bill in Manila on 3 September 2026, gathering roughly 300 stakeholders from business, government, academics, civil society, and media to review the tax reform
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Portugal extends Pillar Two Modelo 62 filing deadline for 2025 tax year
Portugal’s Secretary of State for Fiscal Affairs has extended the deadline for entities subject to the Global Minimum Tax Regime to file the Modelo 62 Registration Declaration for the 2025 tax year. The three-month extension was announced under
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Bahrain: NBR issues DMTT computation guide for 15% domestic minimum top-up tax
Bahrain’s National Bureau for Revenue (NBR) has issued the DMTT Computation Guide Version 1.0 on 23 August 2026, providing guidance on how in-scope Multinational Enterprise (MNE) Groups should calculate the 15% Domestic Minimum Top-up Tax
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Slovak Republic: MoF proposes Pillar Two tax amendments, expanded safe harbours
The Slovak Republic Ministry of Finance has proposed a draft amendment, on 18 August 2026, to Act No. 507/2023 Coll. pertaining to top-up tax, ensuring a global minimum level of taxation for multinational enterprise (MNE) groups and large-scale
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UAE issues Pillar Two QDMTT guidance on scope, registration, excluded entities
The UAE Federal Tax Authority (FTA) has issued two guides dated 26 August 2026 providing administrative and technical guidance on the Qualified Domestic Minimum Top-up Tax (QDMTT) Legislation. The guidance covers how multinational enterprise
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Russia: FTS clarifies Pillar Two corporate tax rules for MNE groups
Russia has introduced special rules for calculating corporate income tax for members of international groups of companies, with the clarifications published by the Federal Tax Service (FTS) in Tax Policy and Practice, No. 8/2026, on 18 August
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