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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.
The Kenya Revenue Authority’s 9 November notice directs covered persons to notify the Commissioner by 30 November 2026, giving the group name, the ultimate parent entity’s country and the Kenyan constituent entities and PINs. Read our updated analysis.
Singapore’s Finance (Income Taxes) Act 2026 (Act 23 of 2026) was assented to on 29 October and published on 4 November. It enacts the Pillar Two amendments passed on 6 October. Sections 36 and 40–48 and section 49(a) and (c) commenced on publication; sections 38 and 49(b) are deemed in force from 1 January 2026; sections 37, 39, 49(d) and 50 await ministerial commencement. Read our updated analysis.
Featured Articles
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
Switzerland adopts a one-year delay to the OECD Article 9.1 DTA guidance for 2024, with foreign IIR and grace-period cap implications.
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