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.
Montenegro brings its PIDP GloBE Information Return rulebook into force
Montenegro’s Rulebook in Official Gazette 143/2026 entered into force on 9 October 2026. It prescribes Form PIDP, XML filing, a pre-deadline filer notice, central-filing relief and local fallback/exchange procedures.
Singapore Parliament passes 2026 Finance Bill with Pillar Two amendments
Singapore’s Parliament passed Bill 22/2026 on 6 October 2026. The Bill advances Side-by-Side safe-harbour powers, GIR exchange and local fallback filing, return-exemption powers, and DTT accounting rules, but still awaits assent and publication.
Thailand consults on a Revenue Department framework for qualified refundable tax credits
Thailand is consulting until 5 November 2026 on legislative principles for a Revenue Department QRTC framework, including electronic certificates, tax settlement, refunds and transfers. The proposal leaves eligibility, rates and commencement to further legislation and rules.
Belgian committee approves DAC9 and QDMTT return deadline bill
A Belgian Chamber committee has unanimously approved a bill implementing DAC9, establishing the domestic framework for centralised GIR exchange and extending the statutory QDMTT return deadline from 11 to 15 months, with an 18-month transitional rule.
Norway proposes a statutory framework for the Pillar Two safe harbours in its 2027 budget bill
Norway’s 2027 budget proposition proposes separate statutory powers for the Pillar Two safe harbours, together with commencement provisions and technical corrections. Most Top-up Tax Act amendments would apply to financial years beginning after 31 December 2025.
Cyprus Proposes a Qualified Domestic Minimum Top-up Tax from 2026
Cyprus has tabled a Pillar Two amendment bill to introduce a qualified domestic minimum top-up tax for financial years beginning from 31 December 2025.
