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The Belgian tax authorities have announced a further extension of several key Pillar Two compliance deadlines:
– QDMTT Return – The filing deadline has been extended to 31 October 2026 for reporting years beginning on or after 31 December 2023 and ending between 1 January 2024 and 31 October 2025.
– IIR Return – The deadline for IIR top-up tax returns that would otherwise become due before 31 October 2026 has been deferred to that date.
–GIR Notification – The deadline for the notification of the GIR filing entity has also been extended to 31 October 2026 for the relevant reporting years covered by the separate announcement.
IN RFB No. 2,342/2026, signed on 15 September 2026 and published on 18 September 2026, amends IN RFB No. 2,228/2024, which regulates Brazil’s Additional Social Contribution on Net Profit (CSLL). The Additional CSLL is Brazil’s qualified domestic minimum top-up tax, introduced by Law No. 15,079/2024.
The principal change is the incorporation of the Substance-Based Tax Incentives Safe Harbour, known in Brazil as the RSGIF. This reflects the OECD’s January 2026 Side-by-Side Package, which allows certain qualifying tax incentives to be treated as an addition to covered taxes, subject to a substance-based cap.
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 Harbour and amend the treatment of certain 52- and 53-week accounting periods. This forms part of the 2027 Tax Plan, although several provisions would apply retrospectively to fiscal years beginning in late 2025 or in 2026.
On 11 September 2026, the OECD released a package of guidance and implementation materials that provides for the exclusion of Explicitly Conditional Taxes from Covered Taxes, clarifies the treatment of mismatched fiscal periods under the Qualified Domestic Minimum Top-up Tax Safe Harbour, updates the GloBE Information Return and establishes the detailed framework for full legislative reviews of domestic minimum tax rules.
Uruguay’s presidential decree dated 31 August 2026 replaces the conditional DMTT payment waiver in Decree No. 325/025 with a compensation mechanism. Article 1 requires in-scope constituent entities allocated DMTT in Uruguay to comply with their DMTT obligations and pay the tax; article 7 repeals the earlier decree.
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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
Uruguay’s presidential decree dated 31 August 2026 replaces the conditional QDMTT payment waiver in Decree No. 325/025 with a compensation mechanism. Article 1 requires in-scope
Qatar has published six decisions dealing with currency conversion, simplified reporting, the Transitional CbCR Safe Harbour, non-material constituent entities, designated local entities and registration.
The Slovak Government has approved draft legislation that would make significant changes to Slovakia’s qualified domestic minimum top-up tax regime. The proposals would implement the
Cyprus has opened a public consultation on amendments to its Pillar Two legislation intended to address observations from the European Commission and align the domestic
On August 7, 2026, Germany published a regulation that gives domestic legal effect to a jurisdiction-by-jurisdiction list of qualifying Pillar Two jurisdictions.
On August 8, 2026, Mauritius issued its QDMTT regulations to implement its QDMTT.
On 3 August 2026, Korea’s Ministry of Finance and Economy released its 2026 Tax Reform Proposal. Among its international tax measures are proposed amendments intended
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