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 MÃnimo 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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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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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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Cyprus: Ministry of Finance consults amendments to Pillar Two taxation law
The Cyprus Ministry of Finance has opened a public consultation on 30 July 2026, on the Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union (Amendment) Law of 2026. The amending bill
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Spain clarifies Pillar Two exclusion for publicly owned commercial entities
Spain's General Directorate of Taxes (DGT) has ruled that publicly owned commercial entities are not automatically excluded from the scope of Pillar Two, and that qualification as an excluded governmental entity must be assessed on a case-by-case
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Germany gazettes amended minimum tax report ordinance
Germany has amended and renamed its Minimum Tax Report Ordinance, restructuring the regulation and adding a comprehensive list of foreign tax jurisdictions recognised for the purposes of the country's Minimum Tax Act, according to a notice published
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Bahrain: NBR publishes guidance on DMTT returns
Bahrain’s National Bureau for Revenue (NBR) has published Version 1.0 of its DMTT Return Filing Manual, setting out procedures for filing, payment and refunds under the 15% Domestic Minimum Top-up Tax (DMTT). The regime applies from 1 January 2025
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Netherlands: Tax Authorities clarify Pillar Two Minimum Tax Act 2024
The Dutch Tax Authorities have updated their Questions and Answers (Q&A) on the Minimum Tax Act 2024 (MTA 2024), providing revised guidance on the application of the legislation, including the treatment of penalties, tax interest, appeal periods
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Qatar: GTA opens registration for global, domestic minimum tax (Pillar Two) on Dhareeba platform
Qatar’s General Tax Authority has announced the launch of the Global and Domestic Minimum Tax (Pillar Two) Registration Service through the Dhareeba platform on 2 August 2026. The GTA invites multinational enterprise (MNE) groups that fall
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Portugal approves forms for calculation, settlement, declaration of domestic top-up tax
Portugal approved Modelo 64 tax return form, the official return for the assessment and payment of domestic top-up tax under the Global Minimum Tax Regime (RIMG), following the launch of the Modelo 62 – Registration Declaration form (RIMG) filing
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Italy introduces payment codes for Pillar Two voluntary disclosure
The Italian Revenue Agency announced, on 23 July 2026, that it has introduced new tax codes for paying penalties through the F24 form for voluntary disclosure of violations relating to the Global Minimum Tax's information and reporting obligations
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Netherlands: CFC levy cannot offset low-tax free investments under participation exemption
The Dutch Tax Administration issued a clarification on 21 July 2026, explaining that the controlled foreign company (CFC) levy does not take low-tax-free investments into account. The recent clarification by the Dutch Tax Administration provides
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Mauritius: Cabinet approves implementation of Qualified Domestic Minimum Top-up Tax (QDMTT)
The Mauritius Cabinet approved new regulations to support the implementation of its Qualified Domestic Minimum Top-up Tax (QDMTT), providing further guidance on the operation of the domestic minimum tax regime introduced in 2025. The Cabinet
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Luxembourg introduces Pillar Two bill with Side-by-Side package
The Luxembourg parliament is considering a draft law submitted on 17 July 2026 that would amend the Law of 22 December 2023 on the minimum effective taxation of multinational enterprise groups and large national groups. The amendments would
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UK: HMRC publishes draft side-by-side package, domestic top-up tax rules for multinationals
HMRC released a policy paper, draft legislation, and explanatory notes on 13 July 2026 covering the introduction of the Side-by-Side package and proposed changes to the UK's Multinational Top-up Tax and Domestic Top-up Tax regimes. Introduction
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Brazil: RFB issues guidance on corporate social contribution on net profit
Brazil’s Federal Revenue Service (RFB) announced  he publication of a guidance on 8 July 2026, detailing the additional Corporate Social Contribution on Net Profit (CSLL) to enforce a 15% minimum tax rate on multinational companies. The CSLL
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UAE updates Pillar Two guidance with OECD 2026 commentary, administrative guidance
The UAE has updated the guidance for its domestic Pillar Two regime by issuing Ministerial Decision No. 96 of 2026 on the Commentary and Agreed Administrative Guidance for the Purposes of Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up
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