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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A practical guide to Luxembourg’s top-up tax return on MyGuichet.lu, including what the local XML does, which fields drive the filing logic, and where groups usually need extra controls.
On February 27, 2026, South Korea issued an amendment to its international tax adjustment decree to provide for detailed provisions for the application of its QDMTT.
In this article we look at how Japan handles the Pillar Two GloBE Information Return through the e-Tax Multinational Enterprise Information Reporting Corner, what fields Japan localises in the GIR XML and CSV package, and how that sits alongside the Japanese top-up tax return.
View our downloadable checklist for Japan’s Pillar Two filing process.
On March 17, 2026, Belgium issued a Circular on Pillar Two Currency Conversion.
On March 19, 2026, Belgium issued a Consultation on the Pillar 2 IIR Top-Up Tax Return.
On March 19, 2026, Switzerland opened up its GIR Filing Portal. Download our Swiss GIR Filing Checklist.
On March 19, 2026, Switzerland opened up its GIR Filing Portal.
On March 10, 2026, Montenegro published its law to implement a global minimum tax (QDMTT) in its Official Gazette.
On March 17, 2026, Spain’s Navarra region published Decree 13/2026, of February 25. 2026 in its Official Gazette. This approves the Global Minimum Tax Regulations for the Navarra Region and applies to tax periods beginning on or after December 31, 2023
On March 12, 2026, Australia updated its guidance on Lodging, paying and other obligations for Pillar Two.
On March 10, 2026, Liechtenstein issued a proposal (for consultation) to amend its Minimum Tax Act to enable it to implement the January 2026 OECD Side-by-Side Tax Package.
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