Find the Pillar Two rules and filing requirements that apply to your group.

In its 9 October 2026 response on Bill 37025, the Dutch Government confirms that the asset-transfer/M&A simplification in proposed Article 8.11d(2)–(4) is optional. It says the choice is an annual election in the GIR; without it, Article 8.11d(1) remains the starting point. The Government declined to amend the wording. The submitted bill’s conditions—unchanged tax bases (apart from goodwill) and corresponding deferred taxes at at least the minimum rate—still govern access. This clarifies how the proposal is intended to operate; it is not enactment or a new safe harbour. Official response, section 4, final answer; Bill, Article 8.11d. Earlier analysis of the bill.

Bermuda’s Tax Credits (Administrative) Regulations 2026 (BR 114/2026), made on 8 October and operative from 9 October, prescribe registration and group claim procedures under the existing Tax Credits Act. Regulation 15 sets the original claim deadline at the end of the tenth month after the fiscal year, subject to the next-business-day rule. The instrument implements existing credit entitlements; it is not a new GIR deadline or an OECD qualification decision. Official regulations; Read our analysis.

Sweden submitted Proposition 2026/27:4 to Parliament on 13 October 2026; it was referred to the Tax Committee on 14 October. This advances the August Council on Legislation referral, but is not parliamentary adoption or enactment.

Proposed Chapter 8, sections 18 a–18 b retain Side-by-Side IIR/UTPR relief and narrower UPE-jurisdiction UTPR relief, subject to an Inclusive Framework-approved regime. The bill also extends the Transitional CbCR Safe Harbour to fiscal years beginning before 1 January 2028 and ending no later than 30 June 2029. Proposed commencement is 1 January 2027, normally for years beginning after 31 December 2026; transitional point 3 permits elective earlier application, with the new Side-by-Side, UPE and qualified-incentive provisions no earlier than years beginning after 31 December 2025. Parliamentary record; Official bill, pages 15–17.

IRAS’s guidance, updated on 13 October 2026, identifies Singapore tax incentives and qualifying components for the Substance-based Tax Incentive Safe Harbour under domestic top-up tax. The guidance distinguishes specified base and enhanced deductions; relief remains elective and subject to the substance cap. This is administrative guidance, not the creation of new deductions or evidence of Finance Bill assent. Official guidance; QTI list. Read our analysis.

Kenya published the Income Tax (Minimum Top Up Tax) Regulations, 2026 (Legal Notice 189) on 18 September 2026. Regulation 27 sets an initial 60-day notification period and rules for later entry and cessation. Regulation 28 distinguishes the local minimum top-up tax return, due by the end of the sixth month after year-end, from the GIR’s 18-month first-year and 15-month subsequent deadlines. The separate statutory payment timetable remains relevant. Read our analysis.

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.