Research domestic rules, compare local compliance obligations and build reports with links to the underlying law. Independent analysis for lawyers, accountants and in-house tax teams.
Analysis by Lee Hadnum — Chartered Accountant and former Senior Tax Analyst at Bloomberg Tax, with 20 years of experience in international tax planning.
Explore the public guide overview, compliance resources and report walkthrough. These show the structure of the research and the outputs available through membership.
A country guide connects domestic implementation to the underlying legislation.
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A high-level view of Pillar 2 implementation and key design features across jurisdictions.
Track local filing requirements, timelines, and practical compliance checkpoints by jurisdiction.
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Assess Transitional CbCR Safe Harbour eligibility by tested jurisdiction and export structured outputs.
Helps tax teams generate workplans, manage GIR filing routes, track local returns and notifications, apply QDMTT jurisdiction-specific tailoring, assess safe harbours, collect evidence and control review/sign-off.
Automated tax engine to calculate whether the Simplified ETR Safe Harbour applies.
Uruguay’s Presidency has published signed IMCD regulations dated 16 October 2026. Articles 27–32 specify the Transitional CbCR Safe Harbour, covering fiscal years beginning on or before 31 December 2027 and ending no later than 30 June 2029. Article 37 assigns the designated local filer responsibility for the return and group payment. The existing 15-month filing period remains; an extension to 18 months for a first transition year requires DGI action. The Presidency copy is listed as Decree S/N/026; a numbered Gazette version and publication date have not been independently verified. Official decree; Read our analysis.
Law No. 2026-963 of 19 October 2026, published in the Official Journal on 20 October, authorises approval of the Multilateral Competent Authority Agreement on the Exchange of GloBE Information, signed by France on 9 July 2025. Parliament definitively adopted the sole authorising article on 7 October. This completes the legislative authorisation stage; it does not by itself establish an active bilateral exchange relationship. Agreement section 8(1)–(2) requires matching notifications from the sending and receiving authorities. Groups should distinguish this authorisation from activation of the relevant exchange relationship. Official promulgation record; Definitive text, sole article; Agreement, section 8.
NAV released form 25GLBADO in ONYA for 2025 top-up taxes and the QDMTT advance, with completion guidance and field definitions. Filing is electronic through ONYA.
For calendar-year FY2025, the advance return and payment are due on 20 November 2026. The annual return and payment are normally due on 31 March 2027, or 30 June 2027 where 2025 is the taxpayer’s transition year. Official NAV announcement; Form and completion guides.
Switzerland adopted the amendment delaying the OECD January 2025 Article 9.1 DTA guidance to fiscal years beginning from 1 January 2025. It enters into force on 15 November 2026. Affected groups should consider foreign IIR exposure and grace-period cap usage. Read our analysis.
The OECD released GIR XML schema version 2.0 and its revised User Guide. Version 1.0 remains applicable to exchanges until 15 June 2028; version 2.0 applies from 25 June 2028, including amendments and corrections. Domestic filing formats depend on local rules. Read our analysis.
Featured Articles
Uruguay’s signed IMCD decree dated 16 October 2026 supplies detailed safe-harbour and compliance rules, including Transitional CbCR Safe Harbour conditions and a designated local filer
Switzerland adopts a one-year delay to the OECD Article 9.1 DTA guidance for 2024, with foreign IIR and grace-period cap implications.
The OECD’s October 2026 GIR XML guide incorporates the revised reporting framework and sets a June 2028 transition for exchanges, including corrections to earlier returns.
Ireland’s Finance (No. 2) Bill 2026 proposes Side-by-Side, UPE and substance-based incentive safe harbours, a simplified-ETR framework and GIR filing and penalty changes, with provision-specific
Bermuda’s Tax Credits (Administrative) Regulations 2026, operative from 9 October, prescribe registration, group filing and a ten-month claim deadline under the existing Tax Credits Act.
IRAS guidance updated on 13 October 2026 identifies Singapore tax incentives and qualifying components for the Substance-based Tax Incentive Safe Harbour, including specified base and
Kenya published final minimum top-up tax regulations on 18 September 2026. Legal Notice 189 sets notification and filing requirements, including distinct local-return and GIR deadlines.
France’s government tabled amendment I-3734 to the 2027 Finance Bill on 10 October 2026. It proposes Side-by-Side and UPE safe harbours, a one-year Transitional CbCR
Montenegro’s Rulebook in Official Gazette 143/2026 entered into force on 9 October 2026. It prescribes Form PIDP, XML filing, a pre-deadline filer notice, central-filing relief
Singapore’s Parliament passed Bill 22/2026 on 6 October 2026. The Bill advances Side-by-Side safe-harbour powers, GIR exchange and local fallback filing, return-exemption powers, and DTT
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