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:
If you haven’t got a subscription you can join up below.
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 expense and transition years. It also provides detailed safe harbours and designated-filer obligations. This analysis explains the changes against the existing DMTT law.
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 application dates.
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. The rules distinguish claims by corporate-tax constituent entities from cash payments for other qualifying entities.
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 enhanced deductions. Relief remains elective and subject to the substance cap.
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. This analysis compares the final rules with the 2025 consultation draft and distinguishes those filing obligations from the existing statutory payment timetable.
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 Safe Harbour extension and related payment and implementation changes. The proposal remains subject to parliamentary processing and enactment.
Montenegro’s Rulebook in Official Gazette 143/2026 entered into force on 9 October 2026. It prescribes Form PIDP, XML filing, a pre-deadline filer notice, central-filing relief and local fallback/exchange procedures.
Singapore’s Parliament passed Bill 22/2026 on 6 October 2026. The Bill advances Side-by-Side safe-harbour powers, GIR exchange and local fallback filing, return-exemption powers, and DTT accounting rules, but still awaits assent and publication.
Thailand is consulting until 5 November 2026 on legislative principles for a Revenue Department QRTC framework, including electronic certificates, tax settlement, refunds and transfers. The proposal leaves eligibility, rates and commencement to further legislation and rules.
A Belgian Chamber committee has unanimously approved a bill implementing DAC9, establishing the domestic framework for centralised GIR exchange and extending the statutory QDMTT return deadline from 11 to 15 months, with an 18-month transitional rule.
This website is not affiliated with or related to the OECD. We provide independent insights and analysis on the OECD Two-Pillar Solution
© 2026 OECDPillars.com
All Rights Reserved