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 June 10, 2026, the EU issued the ‘Manual for MNE Groups on Global Minimum Tax (Pillar Two) Compliance Obligations‘. This provides country level analysis of Pillar Two filings in Austria, Belgium, Croatia, Cyprus, Czech Republic, Finland, France, Germany, Greece, Ireland, Poland, Romania, Slovenia and Sweden.
A practical overview of the Dutch GloBE Information Return (GIR) filing process, including BIA terminology, deadlines, XML format, Digipoort submission, security, validation, notification obligations and governance controls.
Singapore has opened a consultation on the proposed Finance (Income Taxes) Bill 2026, a package that would amend the Income Tax Act 1947 and the Multinational Enterprise (Minimum Tax) Act 2024.
On June 8, 2026, the OECD released the Guidance on the use of the GIR XML Schema for the first GloBE filing and exchange cycle. This provides guidance for the use of the GIR XML Schema for first GloBE filings and exchanges in 2026 including practical fixes, workarounds and the switch-off of certain validation rules.
In June 2026, the Bahamas issued the Domestic Minimum Top-Up Tax (Amendment) Bill, 2026 to provide for administrative and compliance amendments to its QDMTT regime.
On June 4, 2026, the Norwegian Ministry of Finance published a consultation paper proposing amendments to the Norwegian Supplementary Tax Act, to implement the OECD Side-by0Side Tax Package. The consultation deadline is August 3, 2026.
On June 1, 2026, SARS issued the ‘Guide to Submit Global Minimum Tax (GMT) Returns on eFiling’ which explains how MNE groups must access, complete, amend and support South African Global Minimum Tax filings through eFiling.
On June 1, 2026, the Belgian Official Gazette published the Royal Decree of May 25, 2026 determining the 2024 Pillar Two QDMTT Return
On May 20, 2026, the Czech Republic issued Decree No. 68/2026 Coll which prescribes the content structure and electronic format for the Czech Pillar Two tax return and the Czech Pillar Two information return. The decree became effective on 21 May 2026.
The Swedish Tax Agency has updated its public guidance on Sweden’s implementation of the Pillar Two global minimum tax regime.
Germany’s Federal Ministry of Finance published the Draft Annual Tax Act, 2026 on May 19, 2026. Key changes include implementation of aspects of the OECD January 2026 Side-by-Side Package.
On May 18, 2026, the OECD provided three Pillar Two updates: a common understanding among jurisdictions relating to late-filing penalties, further Administrative Guidance on the Transitional UTPR Safe Harbour for 52–53-week fiscal years, and an update to the Central Record.
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