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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Germany: Bundesrat approves Pillar 2 tax amendments, DAC 9 information exchange
Germany ’s Federal Council (Bundesrat) approved a bill (Gesetz zur Anpassung des Mindeststeuergesetzes und zur Umsetzung weiterer Maßnahmen) on 19 December 2025 amending the country’s Pillar 2 minimum taxation framework. The bill updates the
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