Indonesia Issues Regulation PER-6/PJ/2026 on Pillar Two Administrative Requirements
May 13, 2026
On May 4, 2026, Indonesia Issued Regulation PER-6/PJ/2026 on Pillar Two Administrative Requirements.
Paraguay stands out amongst most South American countries as being the one most at risk of substantial jurisdictional top-up tax for in-scope groups under Pillar Two.
Its standard rate of corporate income tax is 10% under Article 21 of Law No. 6,380/19 on the Modernization and Simplification of the National Tax System. This is in contrast to other South American jurisdictions that have much higher standard rates of corporate income tax, such as:
Brazil – 34%
Argentina – 35%
Chile – 27%
Peru – 29.5%
Columbia – 35%
Venezuela – 34%
Guyana – 40%
Mexico – 30%
Nicaragua – 30%
Ecuador – 25%
Bolivia – 25%
Uruguay – 25%
Article 1 of Law No. 6,380/19 on the Modernization and Simplification of the National Tax System establishes a territorial basis for corporate income tax in Paraguay. As such, only income from Paraguayan sources is taxable, subject to a number of exceptions. For instance, Article 6 of Law 6,380/19 provides that Paraguayan source income includes:
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On May 4, 2026, Indonesia Issued Regulation PER-6/PJ/2026 on Pillar Two Administrative Requirements.
On May 6, 2026, Canada issued its Budget 2025 Implementation Act, No. 2 into Parliament. This includes numerous amendments to its Global Minimum Tax Regime.
On May 6, 2026, Switzerland opened a consultation on amendments to the Swiss Minimum Taxation Ordinance, to delay the Swiss application of the OECD January 2025 Administrative Guidance on Article 9.1 of the GloBE Model Rules for one year.
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