Brazil consults on a Simplified ETR safe harbour for its domestic minimum tax
Brazil’s Federal Revenue Service has published draft rules to add a Simplified ETR Safe Harbour to the Additional CSLL from fiscal years beginning on or after 1 January 2027. The consultation closes on 16 November 2026.
Liechtenstein Parliament passes GloBE safe-harbour and GIR-list amendment
Liechtenstein’s Parliament passed amendments replacing the time-limited Article 28 safe-harbour power and adding Government competence for the GIR MCAA list. The measure awaits the referendum and Gazette stages.
Poland passes 22% corporate tax rate tied to Pillar Two group status
Poland’s Parliament has passed a bill that would raise ordinary corporate income tax to 22% for taxpayers that were in scope of Poland’s Pillar Two law in the preceding year, as an alternative to a EUR 50 million local-revenue trigger. The bill awaits presidential action and does not amend Poland’s IIR, UTPR or QDMTT rules.
Ireland updates Pillar Two TIR correction and exchange-code guidance
Ireland Revenue eBrief No. 164/26 adds operational rules for correcting and deleting accepted Top-up Tax Information Returns and for coding the jurisdictions entitled to receive centrally filed GIR data. The 15- and 18-month filing deadlines are unchanged.
Greece prescribes separate domestic top-up tax and IIR/UTPR returns
AADE Decisions A.1236 and A.1237, published on 2 November 2026, prescribe separate domestic top-up tax and IIR/UTPR self-assessment returns. The decisions address designated filers, nil returns, electronic submission and payment under Greece’s existing Pillar Two regime.
Oman gazettes Pillar Two registration, return and enforcement amendments
Royal Decree 101/2026, published in Gazette 1672 on 1 November 2026, rewrites Oman’s Pillar Two registration, filing and payment provisions. Specified amendments apply from the tax year beginning 1 January 2025; the additional enforcement provisions take effect on 2 November 2026.
Curaçao publishes final Pillar Two ordinance: IIR from 2025 and compliance deadlines
Curaçao’s final minimum-tax ordinance introduces an IIR from fiscal years beginning in 2025, reserves domestic-tax and UTPR chapters, and sets separate GIR and tax-return deadlines.
Italy: Restated 2023 Comparatives Do Not Remove a Group from the Pillar Two Scope Test
Italy’s Revenue Agency rejects using lower 2023 comparatives restated under OIC 34 for the 2024 Pillar Two scope test. We examine Response No. 188/2026 and the implications for groups near the €750 million threshold.
Uruguay issues DMTT regulations on GloBE calculations, elections and compliance
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 delays OECD deferred tax asset guidance for 2024
Switzerland adopts a one-year delay to the OECD Article 9.1 DTA guidance for 2024, with foreign IIR and grace-period cap implications.
