Hong Kong Updates its Pillar 2 Guidance for Filing and Registration
On September 26, 2025, Hong Kong updated its Pillar 2 guidance to include information on its Pillar 2 Portal, applications for Group Codes and mandatory e-filing of profit tax returns for Pillar 2 groups.
Germany Issues a Draft Regulation for GIR Filing
On September 29, 2025, the Federal Ministry of Finance opened a consultation on a Draft Regulation for the implementation of the Minimum Tax Act. This provides for compliance rules for the exchange of the GIR and simplified reporting.
Withholding Tax: Double Tax Treaty Planner
A tax modelling tool that calculates the withholding tax rates for interest, dividends and royalties under both domestic law and relevant double tax treaties.
Global Personal Income Tax Modelling Tool
A tax modelling tool that calculates the high-level income tax payable and effective tax rate for different countries.
Intra-Group Loan: Tax Modelling Tool
A tax modelling tool that calculates the effective tax rate for different scenarios in various countries, allowing users to compare the tax implications of different loan structures and jurisdictions
Japan’s Pillar 2 Filing Portal is Open
Japan has launched its Multinational Enterprise Information Reporting Portal for filing Pillar 2 returns.
Nigeria Enacts High-Level GloBE Minimum Tax Rules
On 6 September 2025, Nigeria’s Tax Act 2025 was published in the Official Gazette. This includes a DMTT (without any of the detailed GloBE adjustments yet applying).
Poland Issues Draft Pillar 2 Notifications and Top-Up Tax Returns
On September 11, 2025, the Polish Ministry of Finance issued the draft Pillar 2 notifications and top-up tax returns for consultation.
Vietnam Issues its Pillar 2 Decree
On August 29, 2025, Vietnam issued its Decree for the detailed implementation of the Pillar 2 rules from January 1, 2024.
Czech Republic Gazettes Act No. 316/2025 to Amend its Minimum Tax Act
On September 2, 2025, Act No. 316/2025 Coll was published in the Official Gazette to amend the Minimum Tax Act for various aspects of the OECD Administrative Guidance as well as filing dates, QDMTT amendments and amending the Safe Harbour rules.
