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.
Australia updates its Pillar Two rules: analysis of the 2026 Measures No. 2 amendments
On July 1, 2026, Australia issued the Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2026 Measures No. 2) Rules 2026. This incorporates elements of the OECD Agreed Administrative Guidance issued in December 2023, June 2024 and January 2026.
Cyprus Decree No. 272/2026: incorporation of further OECD Pillar Two guidance and safe harbour dates
On June 26, 2026, Cyprus issued Decree 272/2026 to confirm entry-into-force dates for the main January 2026 OECD safe harbour package
UAE Issues a Ministerial Decision for the OECD Side-by-Side Tax Package
On June 22, 2026, the UAE issued Ministerial Decision No. 96 of 2026 to implement the OECD Side-by-Side Tax Package.
Turkey Pillar Two Filings: Filing Routes and the 31 July 2026 Extension
On June 26, 2026, Turkey announced an extension to the filing of its GloBE tax return and payment from June 30, 2026 to July 31, 2026.
The Dutch Draft Safe-Harbour Bill to Amend the Minimum Tax Act 2024
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.
Cyprus Pillar Two: First-Year GIR Filing Route, Notifications and Forms
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.
