Italy Issues Decrees for Pillar Two Tax Return Filing and Payment
Italy has issued 2 regulations relating to the Administration of the Pillar 2 top-up tax. A November 7, 2025 Decree provides for more information on the rules for the submission of the GloBE tax return. Resolution no. 63 of November 10, 2025 provides for the tax codes to be used for the payment of top-up tax on the F24 payment form.
Finland Issues a Draft Law for OECD Administrative Guidance Amendments
On November 3, 2025, Finland issued a draft law for consultation to amend its Minimum Tax Act for the June 2024 and January 2025 OECD Administrative Guidance.
Mauritius Issues Communique for QDMTT Notifications
A Communique of October 29, 2025 issued by the MRA provides further information on QDMTT Notifications.
Kenya Issues Draft Regulations for Domestic Minimum Tax Implementation
On November 3, 2025, Kenya issued the Draft Income Tax (Minimum Top Up Tax) Regulations, 2025 to provide for the detailed application of the Pillar 2 domestic minimum tax.
GloBE Country Guide: Kenya
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Kenya for accounting periods beginning on or after January 1, 2025. Updated for the draft Regulations issued on November 3, 2025.
Ireland’s 2025 Finance Bill Includes January 2025 OECD Administrative Guidance Amendments
On October 16, 2025, Ireland published its 2025 Finance Bill. This includes amendments for the January 2025 OECD Administrative Guidance, DAC 9 implementation as well as other technical amendments.
South Africa Issues a Government Notice to Extend Certain Pillar 2 Filing Deadlines
On October 28, 2025, Government Notice No. 6763 was issued which extended some of the Pillar 2 filing and notification deadlines.
Spain Issues Final Pillar 2 Forms for Registration, GIR and the Top-Up Tax Return
On October 29, 2025, Order HAC/1198/2025, of October 21 was published in the Official Gazette. This approves the final versions of three specific Pillar 2 forms – Form 240 (registration), Form 241 (the GIR) and Form 242 (the top-up tax return).
Slovakia Approves Law to Implement June 2024 and January 2025 OECD Administrative Guidance
On October 21, 2025, Slovakia’s Parliament approved a law to amend its minimum tax act to provide for the June 2024 and January 2025 OECD Administrative Guidance, as well as EU Directive DAC 9 amendments.
Vietnam Issues Decision 3563/QD-BTC 2025 on Administrative Procedures for the Minimum Tax
On October 21, 2025, Vietnam released Decision 3563/QD-BTC 2025 on the Administrative Procedures for the Minimum Tax. This includes the final forms to be submitted for notification, registration and returns.
