Sweden Enacts Law to Amend its Global Minimum Tax Act for June 2024 OECD Administrative Guidance
On December 10, 2025, Law No. SFS 2025:1461 to amend the Global Minimum Tax Act was published in the Swedish Official Gazette. The purpose of the law is to implement the provisions of the June 2024 OECD Administrative Guidance into domestic law.
Finland Issues Guidance on Allocation of Income & Taxes for Pillar 2
On November 25, 2025, the Finnish Tax Administration published guidance on the allocation of profits/losses and taxes between group entities to take account of the June 2024 OECD Administrative Guidance.
Montenegro Issues a Draft QDMTT Law to apply from January 1, 2026
On November 26, 2025, Montenegro issued a Draft Law to apply a domestic minimum top-up tax (DMTT) from January 1, 2026.
GloBE Country Guide: Montenegro
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Montenegro for accounting periods beginning on or after January 1, 2026. Updated for the draft legislation issued on November 26, 2025.
Turkey Issues QDMTT Return Filing Extension and Opens the Filing Test Environment
On December 1, 2025, Turkey announced an extension in the filing and payment date for the QDMTT return and the opening of a test environment for the submission of the QDMTT return.
Swiss Federal Council Issues Amendments to the Minimum Tax Ordinance for OECD GIR Provisions
On November 26, 2025, the Swiss Federal Council issued an amendment to the Minimum Tax Ordinance to provide for the OECD GIR provisions, as well as some other small amendments.
Hungary Enacts Transitional CbCR Safe Harbour Amendments From its 2025 Autumn Tax Package
On November 19, 2025, Hungary enacted Pillar 2 amendments from the 2025 Autumn Tax Package. This includes some amendments to the operation of the Transitional CbCR Safe Harbour.
Slovakia Issues its QDMTT Return
On November 18, 2025, Slovakia issued its QDMTT Return
Hungary Issues a Draft Regulation for the OECD Safe Harbours
On November 14, 2025, Hungary issued a Draft Regulation (for consultation) to provide for the detailed application of the Pillar 2 Safe Harbours.
Italy Issues Decrees for Pillar Two Tax Return Filing and Payment
Italy has issued 2 regulations relating to the Administration of the Pillar 2 top-up tax. A November 7, 2025 Decree provides for more information on the rules for the submission of the GloBE tax return. Resolution no. 63 of November 10, 2025 provides for the tax codes to be used for the payment of top-up tax on the F24 payment form.
