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Uruguay’s DGI issued Resolution 2400/2026 on 23 October, published on 26 October 2026, prescribing the application procedure for IMCD compensation under pre-existing fiscal stability clauses.
Paragraph 1 requires a sworn compensation declaration before opening the administrative file, including a tax-secrecy waiver confined to information in that declaration for communication to the BEPS Inclusive Framework. Paragraph 2 specifies the dossier: representative and protected-entity evidence, the group structure, an audit report substantiating inability to credit IMCD wholly or partly abroad, and the fiscal-year CbCR with a statement identifying any changes from the preceding year.
The underlying compensation mechanism and IMCD liability already existed under Decree 206/026. Resolution paragraph 3 links compensation to the relevant fiscal-year IMCD return; applying an award toward payment requires a favourable DGI decision before the tax deadline. Filing the request alone does not suspend payment. No new exemption, general deadline extension or OECD qualification is established. Existing compensation analysis.
Indonesia’s Directorate General of Taxes announced that it signed the GIR-MCAA declaration during the 27–29 October 2026 Competent Authorities Conference in Kotor, Montenegro. The authority says automatic GIR exchanges for Indonesia are scheduled to begin in 2027.
This advances the exchange framework but does not establish that any particular bilateral exchange relationship is active. Existing PER-6/PJ/2026, Articles 12(5)–(6), 14–15 and 31, retain the qualifying competent authority agreement and notification conditions relevant to foreign GIR filing. The announcement is not a domestic return or payment deadline extension. Official signing announcement; existing administrative rules.
Sweden submitted Proposition 2026/27:9 on 27 October 2026, advancing the 3 September Council on Legislation referral. It remains a government proposal, not an enacted change.
Proposed Chapter 6, section 2 a would move liability for the full domestic top-up tax allocated to a Swedish-resident joint venture or its Swedish-resident subsidiary from Swedish group constituent entities to the joint venture or subsidiary itself. Related procedural amendments would require its own domestic top-up tax return. The Government aims to address the joint-venture-specific QDMTT Safe Harbour switch-off; the bill is not a new OECD qualification decision.
Proposed commencement is 1 March 2027, normally for fiscal years beginning after 28 February 2027. Earlier application for years beginning after 31 December 2023 would require the joint venture, its subsidiaries and the constituent entities in the relevant group all to elect; it is not automatic retrospective relief. These central measures were already in the September referral. Official bill, sections 2.1–2.2, 4 and 7, and Annex 5.
On 29 October 2026, FPS Finance announced that tax returns due around 31 October 2026 may be filed by 16 November 2026 following the cyberattack affecting MyMinfin and other services. For Pillar Two, the relevant comparison is with affected end-October tax-return deadlines, including the QDMTT and IIR return timetable previously extended to 31 October. This is temporary administrative filing relief, separate from the pending statutory QDMTT deadline amendment. The published general notice does not separately enumerate Pillar Two notifications; it should not be read as extending tax payment dates or reopening an already expired GIR deadline. Official FPS Finance update, 29 October 2026.
At Budget 2026 on 28 October, the UK Government confirmed that Finance Bill 2026–27 will implement the OECD Side-by-Side package and make further amendments to Multinational Top-up Tax and Domestic Top-up Tax. The package was announced on 13 July 2026. This is confirmation of the planned legislation, not enactment or a newly announced safe harbour.
Official Budget statement, OOTLAR paragraph 1.40; updated HMRC impact note. Our July draft analysis, with a dated Budget update.
Featured Articles
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.
The OECD’s October 2026 GIR XML guide incorporates the revised reporting framework and sets a June 2028 transition for exchanges, including corrections to earlier returns.
Ireland’s Finance (No. 2) Bill 2026 proposes Side-by-Side, UPE and substance-based incentive safe harbours, a simplified-ETR framework and GIR filing and penalty changes, with provision-specific
Bermuda’s Tax Credits (Administrative) Regulations 2026, operative from 9 October, prescribe registration, group filing and a ten-month claim deadline under the existing Tax Credits Act.
IRAS guidance updated on 13 October 2026 identifies Singapore tax incentives and qualifying components for the Substance-based Tax Incentive Safe Harbour, including specified base and
Kenya published final minimum top-up tax regulations on 18 September 2026. Legal Notice 189 sets notification and filing requirements, including distinct local-return and GIR deadlines.
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
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