Hong Kong Opens its Pillar 2 E-Filing Portal
January 22, 2026
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On January 23, 2026, Japan’s Ministry of Finance stated that it will amend its Pillar 2 Global Minimum Tax Law as part of its 2026 Tax Reform to reflect the January 2026 OECD Side-by-Side Package.
On January 19, 2026, South Korea issued a Draft Law to amend the Enforcement Decree to the International Tax Adjustment Act. This provides for detailed provisions for the application of the QDMTT and will also extend the Transitional CbCR Safe Harbour by 1 year (as provided in the January 2026 OECD Side-by-Side Package).
On January 19, 2026, the Hong Kong Inland Revenue Department opened its E-filing portal for the submission of Top-Up Tax Notifications.
On January 13, 2026, Turkey announced an extension in the filing and payment date for the QDMTT return for the 2024 tax period from January 15, 2026 to January 28, 2026.
On January 12, 2026, the EU Commission issued Commission Notice C/2026/253. This provides that for the purposes of Article 32 of the EU Minimum Tax Directive (which provides for the application of international safe harbours), the safe harbours outlined in the OECD Side-by-Side agreement are ‘qualifying international agreements on safe harbours’. This applies to the:
-Simplified ETR Safe Harbour;
-Extension of the Transitional CbCR Safe Harbour;
-Substance-based Tax Incentive Safe Harbour;
-Side-by-Side System (the Side-by-Side Safe Harbour and the UPE Safe Harbour).
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