Hungary Issues a Draft Regulation for the OECD Safe Harbours
November 17, 2025
November 17, 2025: Hungary – On November 14, 2025, Hungary issued a Draft Regulation (for consultation) to provide for the detailed application of the Pillar 2 Safe Harbours.
November 14, 2025: Guernsey – Guernsey has opened its Pillar 2 Registration Portal, to appoint the Domestic Filing Entity and register Domestic Constituent Entities.
November 11, 2025: Italy – Italy has issued 2 regulations relating to the Administration of the Pillar 2 top-up tax.
The November 7, 2025 Decree of the Deputy Minister of Economy and Finance provides for more information on the rules for the submission of the GloBE tax return, and for the payment of top-up tax due in Italy.
Resolution no. 63 of November 10, 2025 provides for the tax codes to be used for the payment of top-up tax on the F24 payment form.
November 10, 2025: Finland – On November 3, 2025, Finland issued a draft law for consultation to amend its Minimum Tax Act for the June 2024 and January 2025 OECD Administrative Guidance.
November 10, 2025: Romania – On November 7, 2025, Romania issued the Draft Order for the model and content of the GIR and the double filing relief notification.
November 10, 2025: Liechtenstein – On November 5, 2025, Liechtenstein’s Parliament approved an act for the amendment of Liechtenstein’s Global Minimum Tax Act. The bill is intended to implement domestically the OECD provisions for the exchange of information in the GloBE Information Return (GIR) under the Multilateral Competent Authority Agreement on the Exchange of GloBE Information.
November 6, 2025: Mauritius – A Communique of October 29, 2025 issued by the MRA provides that:
– The QDMTT applies to a resident company forming part of an in-scope multinational enterprise group with a fiscal year ending on or after January 1, 2025;
– The deadlines for QDMTT notifications that are already due, have been extended to 30 November 2025;
– The online portal for making a QDMTT notification is now open.
For all Pillar 2 Developments, see our Pillar Two Developments Tracker.
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On November 14, 2025, Hungary issued a Draft Regulation (for consultation) to provide for the detailed application of the Pillar 2 Safe Harbours.
Italy has issued 2 regulations relating to the Administration of the Pillar 2 top-up tax. A November 7, 2025 Decree provides for more information on
On November 3, 2025, Finland issued a draft law for consultation to amend its Minimum Tax Act for the June 2024 and January 2025 OECD
A Communique of October 29, 2025 issued by the MRA provides further information on QDMTT Notifications.
On November 3, 2025, Kenya issued the Draft Income Tax (Minimum Top Up Tax) Regulations, 2025 to provide for the detailed application of the Pillar
On October 16, 2025, Ireland published its 2025 Finance Bill. This includes amendments for the January 2025 OECD Administrative Guidance, DAC 9 implementation as well
On October 28, 2025, Government Notice No. 6763 was issued which extended some of the Pillar 2 filing and notification deadlines.
On October 29, 2025, Order HAC/1198/2025, of October 21 was published in the Official Gazette. This approves the final versions of three specific Pillar 2
On October 21, 2025, Slovakia’s Parliament approved a law to amend its minimum tax act to provide for the June 2024 and January 2025 OECD
On October 21, 2025, Vietnam released Decision 3563/QD-BTC 2025 on the Administrative Procedures for the Minimum Tax. This includes the final forms to be submitted
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