Poland Issues Draft Pillar 2 Notifications and Top-Up Tax Returns
September 12, 2025
September 12, 2025: Switzerland – On September 12, 2025, the Swiss Federal Council issued the Federal Decree on the Approval of the Multilateral Agreement of the Competent Authorities on the Exchange of Global Anti-Base Erosion Declarations, which ratifies the OECD GIR MCAA.
September 12, 2025: Poland – On September 11, 2025, the Polish Ministry of Finance issued the draft Pillar 2 notifications and top-up tax returns for consultation.
September 11, 2025: Ireland – On September 8, 2025, Ireland released Revenue eBrief No. 170/25 with detailed information on the registration process.
September 9, 2025: Vietnam – On September 8, 2025, the Ministry of Finance announced it is to issue a draft resolution to amend its global minimum tax law to exempt from the QDMTT entities implementing BOT power projects with a Government Guarantee.
September 4, 2025: Portugal – On September 2, 2025, Portugal issued Ordinance No. 290/2025/1 which includes the format for the Pillar 2 registration form (Form 62).
September 3, 2025: Czech Republic – On September 2, 2025, Act No. 316/2025 Coll was published in the Official Gazette to amend the Minimum Tax Act for various aspects of the OECD Administrative Guidance as well as filing dates, QDMTT amendments and amending the Safe Harbour rules.
September 2, 2025: Uruguay – On August 31, 2025, the Ministry of Economy and Finance sent the Draft Budget Law for the period 2025–2029 to Parliament. This includes a domestic minimum tax (intended to be a QDMTT).
September 1, 2025: Vietnam – On August 29, 2025, Vietnam issued Decree 236/2025/ND-CP providing for the detailed provisions for the application of the Pillar 2 Global Minimum Tax rules in Vietnam.
September 1, 2025: Brazil – On August 29, 2025, Brazil issued proposed amendments to its QDMTT Law for consultation to take account of the June 2024 and January 2025 OECD Administrative Guidance and other sundry amendments.
September 1, 2025: Malta – Malta has announced it is to repeal its Article 50 postponement of the EU Minimum Tax Directive and apply the Pillar 2 rules. Further details are to be announced in the Budget.
For all Pillar 2 Developments, see our Pillar Two Developments Tracker.
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On September 11, 2025, the Polish Ministry of Finance issued the draft Pillar 2 notifications and top-up tax returns for consultation.
On August 29, 2025, Vietnam issued its Decree for the detailed implementation of the Pillar 2 rules from January 1, 2024.
On September 2, 2025, Portugal issued Ordinance No. 290/2025/1 which includes the format for the Pillar 2 registration form (Form 62).
On September 2, 2025, Act No. 316/2025 Coll was published in the Official Gazette to amend the Minimum Tax Act for various aspects of the
On August 31, 2025, the Ministry of Economy and Finance sent the Draft Budget Law for the period 2025–2029 to Parliament. This includes a domestic
On August 29, 2025, Brazil issued proposed amendments to Normative Instruction No. 2,228 for consultation to take account of the June 2024 and January 2025
On August 29, 2025, Ordinance No. 21 of August 28, 2025 was published in the Official Gazette. This amends various aspects of the Minimum Tax
On August 26, 2025, Australia issued a list of jurisdictions that have qualified status for the purposes of the income inclusion rule and domestic minimum
On August 27, 2025, the Australian Taxation Office issued a draft legislative instrument (the ‘Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR tax return
The Finance Act 2025, enacted on August 8, 2025, introduces a new Sub-Part AF to the Income Tax Act to include a domestic minimum top-up
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