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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The UK’s His Majesty’s Revenue and Customs (HMRC) has published a guidance, on 30 June 2026, on the process for submitting returns for Pillar Two top-up taxes in the UK, Pillar Two top-up taxes submission of returns (Notice 3). This notice
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Brazil issues compliance guidance for OECD-aligned minimum tax on multinationals
Brazil’s tax authority, the Federal Revenue Service (RFB), announced on 24 June 2026, that it has issued guidance to Constituent Entities of Multinational Business Groups regarding compliance with the CSLL Additional Tax, including requirements
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Philippines: BIR begins preparations for implementation of Pillar Two QDMTT
The Philippines Bureau of Internal Revenue (BIR) announced on 11 June 2026, through a Facebook post, that it has begun preparations for the possible implementation of the proposed Qualified Domestic Minimum Top-Up Tax (QDMTT), a measure pushed by
See MoreBrazil: RFB refines CSLL additional tax framework under GloBE rules
Brazil’s Federal Revenue Service (RFB) has published the Normative Instruction RFB No. 2,329 on 19 June 2026, amending the rules governing the Additional Social Contribution on Net Profit (CSLL) surcharge as per Normative Instruction RFB No. 2,228
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Belgium gazettes decree on QDMTT, IIR return forms for 2025 assessment year
Belgium’s Ministry of Finance has gazetted Royal Decrees establishing the return forms for both the Qualified Domestic Minimum Top-Up Tax (QDMTT) and the Income Inclusion Rule (IIR) for the 2025 assessment year. Both Royal Decrees of 5 June 2026
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