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.
Brazil Implements the SBTI Safe Harbour
On 18 September 2026, Brazil issued IN RFB No. 2,342/2026 to introduce a new framework for the treatment of substance-based tax incentives under its Pillar Two rules.
Netherlands proposes new Pillar Two safe harbours in its 2027 Tax Plan
On 15 September 2026, the Dutch government presented a bill that would introduce four new Pillar Two safe harbours, extend the Transitional Country-by-Country Reporting Safe Harbour and amend the treatment of certain 52- and 53-week accounting periods.
OECD Publishes September 2026 Pillar Two Guidance
On September 11, 2026, the OECD released a package of guidance and implementation materials that provides for the exclusion of Explicitly Conditional Taxes from Covered Taxes, clarifies the treatment of mismatched fiscal periods under the Qualified Domestic Minimum Top-up Tax Safe Harbour, updates the GloBE Information Return and establishes the detailed framework for full legislative reviews of domestic minimum tax rules.
Uruguay Amends Fiscal Stability Compensation for its QDMTT
Uruguay’s presidential decree dated 31 August 2026 replaces the conditional QDMTT payment waiver in Decree No. 325/025 with a compensation mechanism. Article 1 requires in-scope constituent entities allocated QDMTT in Uruguay to comply with its QDMTT obligations and pay the tax; article 7 repeals the earlier decree.
