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.
OECD releases GIR XML schema version 2.0 with June 2028 exchange cutover
The OECD’s October 2026 GIR XML guide incorporates the revised reporting framework and sets a June 2028 transition for exchanges, including corrections to earlier returns.
Ireland proposes Pillar Two safe harbours and GIR penalty changes
Ireland’s Finance (No. 2) Bill 2026 proposes Side-by-Side, UPE and substance-based incentive safe harbours, a simplified-ETR framework and GIR filing and penalty changes, with provision-specific application dates.
Bermuda enacts tax-credit claim and payment rules for its corporate tax regime
Bermuda’s Tax Credits (Administrative) Regulations 2026, operative from 9 October, prescribe registration, group filing and a ten-month claim deadline under the existing Tax Credits Act. The rules distinguish claims by corporate-tax constituent entities from cash payments for other qualifying entities.
Singapore identifies qualifying tax incentives for Pillar Two substance-based relief
IRAS guidance updated on 13 October 2026 identifies Singapore tax incentives and qualifying components for the Substance-based Tax Incentive Safe Harbour, including specified base and enhanced deductions. Relief remains elective and subject to the substance cap.
Kenya’s final minimum top-up tax regulations: notification, returns and elections
Kenya published final minimum top-up tax regulations on 18 September 2026. Legal Notice 189 sets notification and filing requirements, including distinct local-return and GIR deadlines. This analysis compares the final rules with the 2025 consultation draft and distinguishes those filing obligations from the existing statutory payment timetable.
France proposes Side-by-Side safe harbours in a government Finance Bill amendment
France’s government tabled amendment I-3734 to the 2027 Finance Bill on 10 October 2026. It proposes Side-by-Side and UPE safe harbours, a one-year Transitional CbCR Safe Harbour extension and related payment and implementation changes. The proposal remains subject to parliamentary processing and enactment.
