Korea’s 2026 Tax Reform Proposal: Implementing the OECD Pillar Two Side-by-Side Package
On 3 August 2026, Korea’s Ministry of Finance and Economy released its 2026 Tax Reform Proposal. Among its international tax measures are proposed amendments intended to implement significant elements of the OECD/G20 Inclusive Framework’s January 2026 Pillar Two Side-by-Side Package.
UAE FTA establishes Pillar Two registration and deregistration deadlines
Decision No. 12 of 2026 introduces a seven-month registration period, transitional deadlines and a five-year notification regime for UAE entities within the domestic minimum top-up tax framework.
Qatar Opens Pillar Two Registration Portal and Sets 30 November 2026 Deadline
Qatar’s General Tax Authority (GTA) activated its Global and Domestic Minimum Tax registration service through the Dhareeba tax platform on 2 August 2026.
Portugal Publishes Model 64: Pillar Two Top-up Tax Return
On 30 July 2026, the Portuguese Government published Portaria No. 318/2026/1, approving Model 64 – the Pillar Two Top-up Tax Return – and its accompanying completion instructions. The Ministerial Order entered into force and took effect on 31 July 2026.
GloBE Country Guide: Monaco
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Monaco for accounting periods beginning on or after December 31, 2026.
Monaco Proposes a Qualified Domestic Minimum Top-up Tax for Fiscal Years Beginning on or After 31 December 2026
Monaco has published draft legislation introducing a Qualified Domestic Minimum Top-up Tax (QDMTT) for multinational enterprise groups. The measure is contained in Bill No. 1129 on the minimum taxation of multinational enterprise groups, dated 14 July 2026 and received by Monaco’s Conseil National on 28 July 2026.
Canada proposes retrospective correction to transitional CbCR safe-harbour anti-arbitrage rule
On July 23, 2026, Canada has released a proposed targeted amendment to its Global Minimum Tax Act that would broaden the circumstances in which an intra-group financing or investment arrangement must be neutralised when applying the transitional Country-by-Country Reporting (“CbCR”) safe harbour.
Luxembourg Issues Bill No. 8795 to Implement the OECD’s Side-by-Side Pillar Two Package
On July 17, 2026, Bill No. 8795 was deposited in the Luxembourg Chamber of Deputies. This would implement the OECD’s January 2026 Side-by-Side package, introduce the permanent Simplified ETR Safe Harbour and extend the Transitional CbCR Safe Harbour.
Barbados Issues Guidance on 2024 Conditional QDMTT for Mixed Ownership Chains
On July 16, 2026 Barbados issued a guidance note: Qualified Domestic Minimum Top-up Tax (QDMTT): Transitional Rule for Fiscal Year 2024 – Transitional Application of Section 5(4) of the Corporation Top-Up Tax Act, 2024-16.
UK publishes draft legislation to implement the OECD’s Side-by-Side Pillar Two package
On July 13, 2026, the UK government published draft Finance Bill 2026–27 legislation implementing the OECD’s January 2026 Side-by-Side package.
