Netherlands issues policy decree clarifying Pillar Two rules, safe harbours and top-up tax
The Netherlands State Secretary for Finance issued Policy Decree No. 2026-15692 on the Minimum Tax Act 2024 (Wet Minimumbelasting 2024) on 22 September 2026, which was published in Official Gazette No. 32160 on 25 September 2026, providing extensive
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Bulgaria consults on Pillar Two safe harbour package
Bulgaria's Ministry of Finance opened a public consultation on 23 September 2026 on a draft law on Amendments and Supplements to the Corporate Income Tax Act (ZID ZKPO), proposing changes covering the conversion of tax thresholds and penalties into
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Brazil amends Pillar Two QDMTT rules to introduce substance-based tax incentive safe harbour
Brazil has published Normative Instruction RFB No. 2.342 of 15 September 2026 in the Official Gazette on 18 September 2026, amending Normative Instruction RFB No. 2.228 of 3 October 2024, which regulates the Additional Social Contribution on Net
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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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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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Ireland: Revenue updates guidance on Pillar Two effective tax rate
Irish Revenue has published eBrief No. 125/26 on 28 August 2026, updating Tax and Duty Manual Part 04A-01-02, which provides guidance on the operation of the Pillar Two rules on the Global Minimum Level of Taxation for Multinational Enterprise
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Slovak Republic: Government approves draft bill to implement Side-by-Side package
The Slovak Republic government has approved a draft bill amending Act No. 507/2023 Coll., which implements the EU Minimum Taxation Directive. The draft bill was approved by Government Resolution No. 320/2026 on 19 August 2026. The bill introduces
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Australia updates GloBE minimum tax provisions on CFC interaction, deferred tax assets, flow-through entities
Australia has issued the Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2026 Measures No. 2) Rules 2026 (the Amending Rules), introducing minor amendments to the Taxation (Multinational—Global and Domestic Minimum Tax) Rules
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Cyprus aligns Pillar Two rules with latest OECD guidance
Cyprus released Decree No. 272/2026 on 26 June 2026 to incorporate OECD materials released after the country's own Pillar Two legislation took effect. The new decree recognises five key OECD documents: the January 2025 Administrative Guidance,
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UAE adopts OECD side-by-side tax framework
The UAE issued Ministerial Decision No. 96 of 2026 (MD 96/2026), on 22 June 2026, which formally adopts the most recent OECD interpretive materials for the UAE's Qualified Domestic Minimum Top-up Tax (QDMTT) regime. It specifically adopts three
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Norway: MoF consults Pillar Two Side-by-Side Package implementation
The Norwegian Ministry of Finance has launched a public consultation on proposed amendments to the Supplementary Tax Act, introduced in January 2024 to implement the Pillar Two global minimum tax rules. The Act of 12 January 2024 implements
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UK updates qualifying Pillar Two jurisdictions, domestic top-up tax lists
The UK has updated its list of recognised jurisdictions and taxes under the Pillar Two framework, adding four jurisdictions to its recognised Qualified Domestic Minimum Top-up Tax (QDMTT) and accredited QDMTT safe harbour lists while revising the
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Brazil: RFB consults substance-based tax incentive safe harbour rules
Brazil's Federal Revenue Service has initiated a public consultation on significant amendments to Normative Instruction RFB No. 2.228, issued on 3 October 2024. The proposed changes aim to align the country's qualified domestic minimum top-up tax
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Switzerland: FTA clarifies Pillar Two Side-by-Side Package application
The Swiss Federal Tax Administration (FTA) on 7 April 2026 released official statements clarifying how Switzerland will apply the Pillar Two Side-by-Side Package and related administrative guidance on Article 9.1 of the Global Anti-Base Erosion
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Greece confirms UTPR, transitional CbCR safe harbours under Pillar Two enters into force
Greece’s Ministry of Finance (MoF) has confirmed that the undertaxed profits rule (UTPR) and the transitional country-by-country reporting (CbCR) safe harbours under Pillar Two, as established in the Minimum Taxation Directive (2022/2523),
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India: 2026 budget proposes relaxed tax rules for multinationals, reforms safe harbour regime
India's Minister of Finance, Nirmala Sitharaman, delivered the Union Budget for 2026-27 on 1 February 2026. The proposals aim to relax tax rules for multinational companies, which are expected to bring greater certainty to cross-border transactions.
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Japan: Cabinet moves to implement Pillar 2 Side-by-Side Package
Japan’s Cabinet has adopted a decision of 23 January 2026 to bring the country’s Pillar 2 global minimum tax framework in line with the OECD’s Side-by-Side Package released on 5 January 2026. The Cabinet decision outlines several key
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