Brazil Issues a Normative Instruction to Amend its Minimum Tax Act for the June 2024 OECD Administrative Guidance
On October 3, 2025 Normative Instruction RFB No. 2282, of October 2, 2025 was published in the Official Gazette. This includes amendments to Brazil’s DMT Law for the OECD June 2024 OECD Administrative Guidance and other sundry amendments.
Israel Issues a Draft QDMTT Law
On October 5, 2025, Israel published a consultation on a draft law for a domestic minimum tax (intended to be a Qualified Domestic Minimum Top-Up Tax or ‘QDMTT’) from January 1, 2026.
GloBE Country Guide: Israel
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Israel for accounting periods beginning on or after January 1, 2026. Updated for the draft legislation issued on October 7, 2025.
Turkey Issues a Draft Communique for Detailed Pillar 2 Implementation
On October 3, 2025, Turkey published the Draft Communique on the Minimum Tax Law, and the Draft GIR, for consultation. Whilst Turkey has enacted its Minimum Tax Law, a lot of the detailed application of the GloBE rules was left to a further Regulation. This Communique therefore provides for the detailed rules for the implementation of the GloBE rules in Turkey.
Croatia Issues a Draft Law to Amend its QDMTT Accounting Standard
On September 18, 2025, Croatia opened a consultation on a Draft Bill to amend its Minimum Tax Act. The amendments are primarily to amend the QDMTT accounting standard so that the Croatian QDMTT qualifies for the QDMTT Safe Harbour and to provide for the notification deadline for appointing a designated filing entity.
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
