Global Minimum Tax
In Today’s 2023 Budget, Hong Kong’s Financial Secretary confirmed that Hong Kong will implement the Pillar Two Global Minimum Tax from 2025.
They estimate that it will generate tax revenue of $15 billion per year for the Government. A consultation is to be launched to allow MNE groups to make early preparation.
It was also announced that Hong Kong will be introducing a Patent Box.
Given the significant foreign direct investment (FDI) into Hong Kong (in 2021 FDI inflows into Hong Kong were US$140.7 billion, the 3rd highest globally behind the United States and Mainland China), it is expected that there will be other ancillary adjustments over the next 2 years to the domestic tax regime to ensure Hong Kong remains internationally competitive after the GloBE rules are introduced.
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On June 16, 2026, the Dutch Ministry of Finance opened an internet consultation on the Draft Safe-Harbour Bill. The consultation closes on 14 July 2026 and provides draft legislation to implement the OECD Side-by-Side package into the Dutch domestic regime.
On June 15, 2026, the Cyprus Tax Department issued two announcements on the domestic implementation of the Pillar Two framework. The first concerned the European Commission’s position on Cyprus’ Income Inclusion Rule (IIR). The second addressed filing deadlines and compliance obligations for Cypriot constituent entities and joint ventures under Law 151(I)/2024.
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.
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