On November 26, 2025, the UK issued a Policy Paper with further planned amendments to its Minimum Tax Law. These include:

• adjustments to provisions that set out how pre-regime deferred tax assets should be treated 

• technical amendments to the clawback provisions that apply to tax equity partnerships 

• simplified calculations for non-material members 

• changes to the rules allowing the profits of a flow-through ultimate parent entity to be reduced 

• adjustments to the election to exclude intra-group transactions 

• adjustments to the recognition of payments for group relief as a covered tax for Domestic Top-up Tax 

• technical adjustments to the test of whether de-merged groups meet the revenue threshold 

• technical adjustments to the application of Part 3 to permanent establishments 

• adjustments to the method for converting Domestic Top-up Tax amounts into sterling 

• changes to the test of whether an instrument is to be regarded as equity or debt 

• a provision under Multinational Top-up Tax which disapplies another jurisdictions’ Qualified Domestic Minimum Top-up Tax safe harbour where the Qualified Domestic Minimum Top-up Tax does not apply to securitisation vehicles 

• a provision which ensures no liability under the undertaxed profits rule can be applied to a securitisation vehicle 

• a provision which removes profits and losses relating to Real Estate Investment Trusts from adjusted profits for the purposes of Domestic Top-up Tax 

• a provision for certain overseas undertaxed profits taxes to have qualifying status in the UK prior to the making of UK regulations and ahead of the outcomes of the ongoing process for international agreement on qualification of undertaxed profits taxes 

• technical adjustments to cater for foreign Qualified Income Inclusion Rules and Qualified Domestic Minimum Top-up Taxes whose application is subject to an election or claim 

• technical adjustments to clarify the location of a stateless entity 

• technical adjustments to resolve double counting in relation to tax transparent investment entities 

• technical adjustments to the cross-border allocation of deferred tax  

• technical adjustments to the allocation of CFC mobile income 

• technical adjustments to clarify the meaning of underlying profits and underlying profits accounts 

• other minor amendments and corrections 

On November 26, 2025, the Swiss Federal Council approved an amendment to the Swiss Minimum Tax Ordinance to provide for the OECD provisions relating to the submission of GloBE Information Returns, including the guidance issued in January 2025.

On November 19, 2025, Hungary gazetted Law No. 2025 LXXXIII to enact the changes to the Transitional CbCR Safe Harbour as proposed in the 2025 Autumn Tax Package.

On November 18, 2025, Slovakia issued its QDMTT Return.

On November 17, 2025, the Belgian tax authorities officially confirmed that the deadline for filing the QDMTT returns for reporting years:

– beginning on December 31, 2023 or later, and
– ending on June 30, 2025 at the latest,

is extended until June 30, 2026.

On November 14, 2025, Hungary issued a Draft Regulation (for consultation) to provide for the detailed application of the Pillar 2 Safe Harbours.

Guernsey has opened its Pillar 2 Registration Portal, to appoint the Domestic Filing Entity and register Domestic Constituent Entities.

Our OECD Pillar Two Tracker covers the latest developments at the OECD, EU and in domestic jurisdictions to keep you up-to-date with the implementation of Pillar Two.

Updated daily and with links to our more detailed analysis on the approach and impact of domestic implementation:

Pillar Two Developments Tracker