Romania consults on draft legislation to ratify Pillar Two STTR instrument
Romania’s government has initiated a public consultation on a draft law to ratify the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI). In September 2023, the OECD/G20 Inclusive Framework
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Belgium releases draft domestic top-up tax return form
Belgium's Federal Public Service (SPF) Finance released an updated draft of the annual supplementary national tax return form on 10 April 2024. This supplementary national tax return form underwent public consultation in October 2024 and has
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OECD releases statement on outcomes of 17th inclusive framework meeting held on 7-10 April
The OECD released a public statement summarizing the key outcomes of the 17th plenary meeting of the OECD/G20 Inclusive Framework on BEPS, which took place from 7-10 April 2025 in Cape Town, South Africa. Domestic tax base erosion and profit
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EU: Council adopts DAC9 to support Pillar Two filings
The Council of the EU announced on 14 April 2025 the formal adoption of changes to the Directive on administrative cooperation in taxation (Directive 2011/16/EU) to simplify filing obligations under the Pillar 2 Directive (DAC9). The directive
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Poland updates law to include new Pillar Two administrative guidelines
Poland's Ministry of Finance is working to finalise a draft legislation to amend the Equalization Tax Act for International and Domestic Groups, implementing the Pillar Two global minimum tax under EU Directive 2022/2523 of 14 December 2022. This
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Brazil updates rules on social contribution top-up tax for Pillar 2
Brazil has issued Normative Instruction RFB No. 2.259 of 24 March 2025, which amends the regulations for the Additional Social Contribution on Net Profit (CSLL) contained in Normative Instruction RFB No. 2,228 of 3 October 2024. The Additional
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OECD adds Guernsey to list of qualified Pillar Two jurisdictions
The OECD issued an update on 31 March 2025, in which Guernsey has been added as a jurisdiction with a qualified income inclusion rule (IIR), domestic minimum top-up tax rule (QDMTT), and meeting QDMTT safe harbor standards. This should prevent
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Spain gazettes Pillar Two global minimum tax rules
Spain has issued Royal Decree 252/2025 of 1 April 2025 in the Official Gazette, introducing Complementary Tax Regulations to ensure a global minimum tax for large multinationals and national groups. The regulations clarify Law No. 7/2024 of 20
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UK lists territories with qualifying IIR and DMTT under Pillar Two rules
The UK’s Pillar Two Multinational Top-up Tax (MTT) rules recognise certain foreign income inclusion rules (IIR) and domestic top-up taxes as "qualifying" if they align with OECD standards. To provide clarity, the government introduced regulations
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Qatar introduces Pillar Two global minimum tax rules
Qatar has enacted the Global Minimum Tax (GMT) rules through Law No. 22 of 2024, which was published in the Official Gazette on 27 March 2025. Law No. 22 of 2024 amends Income Tax Law No. (24) of 2018 and establishes an Income Inclusion Rule
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Finnish issues guidance on Pillar Two global minimum tax
Finland’s tax administration has released two guidance documents on the Minimum Tax Act, approved in late 2023 to implement the Pillar 2 global minimum tax under Council Directive (EU) 2022/2523. The first guidance was released on 10 March
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Italy gazettes decree on global minimum tax form
Italy’s Ministry of Economy and Finance has published the Ministerial Decree of 25 February 2025 in the Official Gazette No. 54 on 6 March 2025. As previously reported, the decree sets rules for companies subject to the global minimum tax on
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Australia: ATO drafting guidance on Pillar Two lodgment obligations and transition
The Australian Taxation Office (ATO) has updated its advice and guidance plans on international issues, including the Pillar Two global minimum tax. This covers Pillar Two lodgment obligations, the ATO's transitional approach, and updated advice on
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Hong Kong announces 2025-26 budget, proposes reducing profits tax amongst other measures
Hong Kong Financial Secretary Paul Chan delivered the 2025-26 budget on 26 February 2025, which included various tax measures such as reducing profits tax, salaries tax and tax under personal assessment; raising the maximum value of properties
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Hungary: Economy minister seeks review of global minimum tax
Hungary's National Economy Minister, Márton Nagy, has called for a reassessment of the global minimum tax following the Trump administration's decision to withdraw the US from its commitment to the OECD Global Tax Deal, also known as the two-pillar
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Poland publishes list of qualified jurisdictions for Pillar Two rules
Poland’s Minister of Finance has issued a notice on 7 February 2025 listing jurisdictions that have adopted the qualified income inclusion rule (IIR), qualified for the domestic minimum top-up tax (QDMTT), or meet the criteria to be treated as
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France gazettes Finance Law 2025
France’s Finance Law 2025 has been published in the Official Gazette, introducing key measures, such as temporary taxes on high-income individuals and large corporations, revisions to the Pillar Two global minimum tax rules, and a new tax on share
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EU Parliament approves positive opinion on DAC9
The European Parliament has adopted its opinion on the proposal to amend the Directive on Administrative Cooperation (2011/16), known as DAC, on 12 February 2025. The proposal seeks to simplify filing and reduce the administrative burden for MNEs
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