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.
Uruguay Budget Bill Includes a Pillar 2 Domestic Minimum Tax
On August 31, 2025, the Ministry of Economy and Finance sent the Draft Budget Law for the period 2025–2029 to Parliament. This includes a domestic minimum tax (intended to be a QDMTT).
GloBE Country Guide: Uruguay
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Uruguay for accounting periods beginning on or after January 1, 2026. Updated for the 2025-2029 Draft Budget Bill.
Romania Adopts a Law to Amend its Minimum Tax Act
On August 29, 2025, Ordinance No. 21 of August 28, 2025 was published in the Official Gazette. This amends various aspects of the Minimum Tax Act, including for the filing deadline for the designated filing entity nomination, transferable tax credits and the excess negative tax carry forward election.
Australia Issues a List of Jurisdictions that Have Qualified IIRs and DMTTs for Pillar 2
On August 26, 2025, Australia issued a list of jurisdictions that have qualified status for the purposes of the income inclusion rule and domestic minimum tax (including the QDMTT Safe Harbour).
Australia Issues a Draft Instrument for IIR/UTPR/QDMTT Filing Exemptions
On August 27, 2025, the Australian Taxation Office issued a draft legislative instrument (the ‘Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR tax return and Australian DMT tax return) Determination 2025’). This outlines situations when entities within the scope of the Pillar 2 GloBE rules do not need to file an Australian DMT Return or an IIR/UTPR Return.
Mauritius Enacts a QDMTT From July 1, 2025
The Finance Act 2025, enacted on August 8, 2025, introduces a new Sub-Part AF to the Income Tax Act to include a domestic minimum top-up tax (intended to be a QDMTT) from July 1, 2025.
GloBE Country Guide: Mauritius
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in the Czech Republic for accounting periods beginning on or after July 1, 2025. Updated for the Finance Act 2025, enacted on August 8, 2025.
IIRs and DMTTs that don’t yet Qualify Under the OECD August 2025 Update
On January 15, 2025, the OECD issued Administrative Guidance that includes a list of jurisdictions that have transitional qualified status for the purposes of the income inclusion rule and domestic minimum tax (including the QDMTT Safe Harbour). This was subsequently updated on March 31, 2025 and August 18, 2025.
