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The Fiscale verzamelwet 2027 (Staatsblad 2026, 376), dated 28 October and published on 11 November 2026, expressly includes actual foreign qualified domestic minimum top-up tax in the actual-tax routes for the Dutch participation credit and foreign business profits credit. Article V(B)–(C) adds Corporate Income Tax Act Articles 23c(10) and 23d(7); Article XXIX brings these provisions into force on 1 January 2027. This concerns credits for non-qualifying investment participations and low-tax foreign investment enterprises, rather than a new Pillar Two charge. The explanatory memorandum (§2.7 and the Article V notes) states that no substantive change is intended. The Government’s response (§2.5) retains the need to demonstrate the foreign tax actually paid in respect of the relevant distribution or enterprise profit; the measure does not confer an automatic credit for every group QDMTT payment.
Treasury’s Tranche 4 consultation, open from 11 to 26 November, proposes annual Side-by-Side and UPE safe-harbour elections for fiscal years starting on or after 1 January 2026, subject to ministerial jurisdiction determinations. Domestic minimum tax remains unaffected by those safe harbours. The exposure draft also amends deferred-tax recapture tracking and transparent-entity rules. These are proposals, not enacted relief or a new filing deadline. Read our analysis.
FURS published a dedicated substance-based tax incentive (SBTI) explanation on 3 November and updated its general and procedural explanation on 5 November 2026. The SBTI explanation expressly covers financial years beginning on or after 1 January 2026, including Slovenian domestic top-up tax, and maps existing domestic incentives to qualified tax incentive treatment, subject to elections and the substance cap. The general explanation covers the other January 2026 OECD safe harbours and the transitional CbCR extension under the existing statutory framework. These are administrative explanations, not a new tax or new ordinary corporate-tax incentive. Official announcements; SBTI explanation, sections I–IV; general explanation, sections 4.1–4.2; Slovenia guide.
Royal Decree 105/2026, issued on 10 November 2026, expressly applies the existing Top-up Tax Law to entities belonging to multinational groups in the Oman International Financial Centre. Article II provides for commencement on the day after Official Gazette publication; a Gazette publication date has not been verified. The decree adds a specific application rule to the centre’s separate legal framework. It does not prescribe a new rate, return or payment deadline, or establish that every centre business is liable. Official decree announcement and text.
Brazil’s Federal Revenue Service has opened a consultation, closing on 16 November 2026, on draft amendments to the Additional CSLL. The proposal would introduce an annual Simplified ETR Safe Harbour for fiscal years beginning on or after 1 January 2027, subject to jurisdictional, accounting and integrity conditions. The consultation is not enacted law. Official notice; draft instructions; our analysis.
Featured Articles
Australia’s November exposure draft proposes annual Side-by-Side and UPE safe harbours from 2026, while preserving domestic minimum tax. Consultation closes on 26 November.
Brazil’s Federal Revenue Service has published draft rules to add a Simplified ETR Safe Harbour to the Additional CSLL from fiscal years beginning on or
Liechtenstein’s Parliament passed amendments replacing the time-limited Article 28 safe-harbour power and adding Government competence for the GIR MCAA list. The measure awaits the referendum
Poland’s Parliament has passed a bill that would raise ordinary corporate income tax to 22% for taxpayers that were in scope of Poland’s Pillar Two
Ireland Revenue eBrief No. 164/26 adds operational rules for correcting and deleting accepted Top-up Tax Information Returns and for coding the jurisdictions entitled to receive
AADE Decisions A.1236 and A.1237, published on 2 November 2026, prescribe separate domestic top-up tax and IIR/UTPR self-assessment returns. The decisions address designated filers, nil
Royal Decree 101/2026, published in Gazette 1672 on 1 November 2026, rewrites Oman’s Pillar Two registration, filing and payment provisions. Specified amendments apply from the
Curaçao’s final minimum-tax ordinance introduces an IIR from fiscal years beginning in 2025, reserves domestic-tax and UTPR chapters, and sets separate GIR and tax-return deadlines.
Italy’s Revenue Agency rejects using lower 2023 comparatives restated under OIC 34 for the 2024 Pillar Two scope test. We examine Response No. 188/2026 and
Uruguay’s signed IMCD decree dated 16 October 2026 adds previously missing GloBE elections and develops the rules for income, covered taxes, foreign-tax allocation, negative tax
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