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June 12, 2025: Spain – On June 3, 2025, the draft Pillar 2 forms were issued for public consultation. This includes Form 240 (registration), Form 241 (the GIR) and Form 242 (the top-up tax return).
June 11, 2025: Iceland – On June 5, 2025, Iceland opened a consultation on a draft bill to implement an IIR and QDMTT under the OECD Pillar 2 GloBE rules.
June 10, 2025: Mauritius – In the 2025 Budget speech delivered on June 5, 2025, Mauritius proposed a Domestic minimum top-up tax (DMTT) effective for income derived on or after July 1, 2025.
June 6, 2025: Denmark – On June 3, 2025, Bill 2024/1 LSV 194 A to amend the Danish Minimum Tax Act for the June 2024 and January 2025 OECD Administrative Guidance was passed by Parliament.
June 6, 2025: Hong Kong – The Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025 has been published in the Official Gazette. The law is now enacted.
May 29, 2025: Kenya – Section 7 of the 2025 Finance Bill (sent to Parliament on May 7, 2025), provides that the DMTT is payable by the end of the fourth month following the end of the fiscal year.
May 28, 2025: Hong Kong – The Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024 was passed by the Legislative Council on May 28, 2025. It now needs to be signed by the Chief Executive and published in the Official Gazette.
May 20, 2025: Hungary – On May 13, 2025, Bill T/11920 was issued (the 2025 Spring Tax Package). This includes a provision to amend the Pillar 2 registration deadline to 2 months after the end of the relevant tax year.
For all Pillar 2 Developments, see our Pillar Two Developments Tracker.
Featured Articles
On June 3, 2025, the draft Pillar 2 forms were issued for public consultation. This includes Form 240 (registration), Form 241 (the GIR) and Form
On June 5, 2025, Iceland issued a Draft Minimum Tax Bill for consultation. The Draft Bill includes an Income Inclusion Rule (IIR) and a domestic
On June 6, 2025, the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025 was published in the Official Gazette. The Bill includes
On June 3, 2025, the Danish Parliament passed Bill 2024/1 LSV 194 A to amend the Danish Minimum Tax Act for the June 2024 and
The GloBE rules include a number of insurance specific adjustments. In this article we look at the nature of these provisions as well as the
Whilst the treatment of investment property for financial accounting purposes is important when determining the GloBE treatment, of even more importance are any differences between
Top-up taxes under a QDMTT are added to covered taxes of a CFC but only for the purposes of calculating the allocation of Blended CFC
The clarifications and additions to the Commentary to the Pillar Two GloBE Rules provided by the OECDs Administrative and Safe Harbours Guidance, means that there
Section 20 of Bill T/11920 of May 13, 2025 (issued as part of the 2025 Spring Tax Package), proposes to amend the registration deadline to
The definition of CFC taxes that are restricted in the GloBE rules is much narrower than under many domestic CFC regimes. In this article we
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