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.
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Assess Transitional CbCR Safe Harbour eligibility by tested jurisdiction and export structured outputs.
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France’s Government tabled amendment I-3734 to the 2027 Finance Bill on 10 October 2026. It proposes elective Side-by-Side and UPE safe harbours for fiscal years beginning on or after 1 January 2026 and a one-year Transitional CbCR Safe Harbour extension. The proposed Side-by-Side relief concerns IIR and UTPR, leaving the French domestic charge intact. The Assembly records the amendment as under processing, subject to admissibility; it is not adopted or enacted. Official amendment. Read our analysis.
Denmark’s legislative programme, dated 6 October 2026, schedules a bill amending the Minimum Tax Act for the second half of December 2026. The announced purpose is to implement the January 2026 OECD agreement, including equivalence treatment for other jurisdictions’ minimum-tax rules. This is a legislative-programme announcement, not a published bill or enacted change; the programme does not specify operative commencement or transition rules. Official programme, page 46.
On 9 October 2026, Belgium’s Council of Ministers approved a preliminary draft law assenting to the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA), signed by Belgium on 16 June 2025. The draft has been referred to the Council of State for an opinion. This is a preparatory legislative step, not enactment, completed ratification or activation of exchange relationships. It is distinct from the DAC9 bill previously covered. Official government release.
Montenegro’s Rulebook on the content, method and deadline for submitting the GloBE Information Return and notification of the submitting constituent entity (Official Gazette No. 143/2026) was published on 1 October 2026 and entered into force on 9 October. It prescribes Form PIDP, electronic XML filing, notification of the filing entity at least 30 days before the GIR deadline, central-filing relief, local fallback filing and exchange timelines. Official Gazette record; read our analysis.
Germany’s Act approving the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (BGBl. 2026 II No. 220), dated 30 September, was promulgated on 5 October 2026 and entered into force on 6 October. Article 1 approves the agreement; Article 2(2) provides that the agreement’s own entry into force for Germany under section 8(2) will be announced separately. The Act therefore completes domestic legislative approval but does not by itself activate exchange relationships. Under section 3, first-year exchanges are due within six months after the filing deadline and subsequent exchanges within three months, subject to the reciprocal notifications required by section 8. Official Gazette; Act and agreement text.
Romania deposited its instrument of ratification of the STTR Multilateral Convention on 2 October 2026. The OECD records entry into force for Romania on 1 February 2027. Its deposited position lists 23 tax agreements and elects Article 12(5), which makes entry into effect dependent on notifications confirming completion of internal procedures for the relevant agreement. The February entry-into-force date is therefore not a general STTR tax commencement date; treaty coverage and effective fiscal years require bilateral checks. Official depositary status; Romania’s deposited position, Articles 2 and 12.
Featured Articles
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
Thailand is consulting until 5 November 2026 on legislative principles for a Revenue Department QRTC framework, including electronic certificates, tax settlement, refunds and transfers. The
A Belgian Chamber committee has unanimously approved a bill implementing DAC9, establishing the domestic framework for centralised GIR exchange and extending the statutory QDMTT return
Norway’s 2027 budget proposition proposes separate statutory powers for the Pillar Two safe harbours, together with commencement provisions and technical corrections. Most Top-up Tax Act
Cyprus has tabled a Pillar Two amendment bill to introduce a qualified domestic minimum top-up tax for financial years beginning from 31 December 2025.
On 18 September 2026, Brazil issued IN RFB No. 2,342/2026 to introduce a new framework for the treatment of substance-based tax incentives under its Pillar
On 15 September 2026, the Dutch government presented a bill that would introduce four new Pillar Two safe harbours, extend the Transitional Country-by-Country Reporting Safe
On September 11, 2026, the OECD released a package of guidance and implementation materials that provides for the exclusion of Explicitly Conditional Taxes from Covered
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