Poland: Council of Ministers passes DAC8, DAC9
Poland’s Ministry of Finance announced, on 17 December 2025, that the Council of Ministers approved a draft bill to implement Council Directive (EU) 2023/2226 of 17 October 2023 (DAC8) and Council Directive (EU) 2025/872 of 14 April 2025
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Netherlands: Senate approves 2026 Tax Plan package
The Netherlands Senate approved the legislative proposals contained in the 2026 Tax Plan package on 16 December 2025. The measures will enter into force once they receive royal assent and are published in the Official Gazette. The Ministry of
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Netherlands: Tax Authority publishes guidance on pillar two for low-taxed intra-group transfers
The Netherlands Tax Administration has issued a guidance 15 December 2025 on calculating the amount of income inclusion top-up tax also known as the income inclusion rule (IIR), in the event of an internal transfer of a low-tax group entity between
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Australia: ATO updates guidance on Pillar 2 interactions with consolidation
The Australian Taxation Office (ATO) released new guidance on 17 December 2025 clarifying how Pillar 2 global minimum tax rules interact with tax consolidation for multinational enterprise (MNE) groups operating in Australia. Australian tax
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Denmark: Parliament approves DAC9 implementation, enables central Top-up tax filing
Denmark's Parliament passed Bill L 23 on 27 November 2025, introducing measures to implement Council Directive (EU) 2025/872 of 14 April 2025 (DAC9). The updated rules allow the automatic exchange of Top-up tax information returns under Directive
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Estonia: MoF rejects OECD Pillar 2 minimum tax amendments
Estonia did not approve the proposed amendments to the minimum tax rules presented under the OECD silent procedure on the Pillar 2 Side-by-Side System Package. The country is seeking a solution acceptable to all parties. This announcement was
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Estonia, Latvia, Lithuania, Malta, Slovakia ask EU to review minimum tax directive
Estonia, along with Latvia, Lithuania, Malta, and Slovakia, submitted a joint statement to EU finance ministers on Friday, 13 December 2025, calling for fairer taxation of international companies and a reduction in administrative burdens. Finance
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Netherlands: Tax Administration clarifies correction of pre-Pillar 2 tax charges under minimum tax Act 2024
The Dutch Tax Administration has confirmed that corporate income tax expenses or benefits relating to pre-Pillar Two financial years must be corrected when calculating adjusted covered taxes under the Minimum Tax Act 2024 (Wet minimumbelasting 2024;
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Turkey: Revenue Administration finalises Pillar 2 Global Minimum tax rules
The Turkish Revenue Administration finalised the implementation rules for the Pillar 2 Global Minimum Tax (GMT) and submitted the General Communiqué to the Presidency for signature and publication. This announcement was made on 12 December
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Hungary enacts 2026 autumn tax reforms, additional measures
Hungary has enacted several significant tax measures through legislative acts to reduce administrative burdens, promote business investment, and align domestic rules with EU directives. The measures are scheduled to take effect in 2026 unless
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Austria: Nationalrat approves Tax Amendment Act 2025
Austria’s National Council (Nationalrat) approved the Tax Amendment Act 2025 (Abgabenänderungsgesetz 2025) on 10 December 2025, introducing extensive changes across federal tax and administrative laws. The legislation amends a wide range of
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Croatia: Parliament adopts Pillar 2 amendments, aligns with OECD GloBE framework
Croatia’s parliament adopted amendments to the Bill on Amendments to the Global Minimum Corporate Tax Act on 5 December 2025, to bring the national rules entirely in line with the OECD GloBE framework and the requirements of EU Directive
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Uruguay: Senate amends Budget Bill to amend QMDTT effective date
Uruguay’s Senate has confirmed the effective date for the qualified minimum domestic top-up tax (QMDTT) in the 2025–2029 Budget Bill amendments on 3 December 2025. The Senate-approved amendments establish that the tax will take effect from
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France: Tax authority issues guidance on Pillar 2 global minimum tax
France’s tax authority has updated its guidance on the Pillar 2 global minimum tax to clarify reporting requirements under the complementary tax regime introduced in the 2024 Finance Law on 9 December 2025. The guidance highlights the release of
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Croatia enacts DAC8, DAC9 requirements
Croatia has gazetted the Law on Amendments to the Act on Administrative Cooperation in the Field of Taxation on 3 December 2025. The law implements Council Directive (EU) 2023/2226 of 17 October 2023 (DAC8) and Council Directive (EU) 2025/872 of
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UAE: MoF publishes domestic minimum top-up tax guidance, FAQs
The UAE Ministry of Finance has released guidance and FAQs regarding the Domestic Minimum Top-up Tax, effective from 1 January 2025. Domestic Minimum Top-up Tax in the UAE (the "UAE DMTT") is applied to Constituent Entities that are members of
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Singapore: IRAS expands GloBE, DTT guidance with comprehensive new e-learning modules
The Inland Revenue Authority of Singapore has published a new suite of e-learning resources that provide in-depth guidance on the Global Anti-Base Erosion (GloBE) Rules and the Domestic Top-up Tax (DTT). The materials span eight main modules—each
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Australia: ATO releases sample forms for global and domestic minimum tax filings
The Australian Taxation Office (ATO) has updated its guidance on lodging, paying, and other obligations under Pillar Two, releasing two sample forms: Combined Global and Domestic Minimum Tax Return for a Group Entity (GE) Combined Global
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