Poland Issues a Draft Law to Implement OECD Administrative Guidance
On February 13, 2026, Poland issued a draft law to amend its Global Minimum Tax Law for the December 2023, June 2024 and January 2025 OECD Administrative Guidance. This also includes QDMTT changes, including the introduction of a Local Financial Accounting Standard rule.
Qatar Issues Cabinet Resolution for Detailed IIR and QDMTT Implementation Rules
On February 12, 2026, Cabinet Resolution No. (2) of 2026, was published in the Official Gazette to provide for the detailed implementation of the IIR and QDMTT in Qatar.
Italy Approves Model for the GloBE Tax Return
On February 6, 2026, the Italian Revenue Agency approved the model for the GloBE tax Return. This is a consolidated form with information on the calculation of top-up tax under the IIR, UTPR and QDMTT.
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Canada’s January 2026 Draft Amendments to the Global Minimum Tax Act: the Elective Private Investment Entity De-Consolidation Regime
On January 29, 2026, Canada’s Department of Finance released draft GMTA technical amendments introducing an elective private investment entity de-consolidation rule for Pillar Two/GMTA purposes.
Japan Issues Guidance on its UTPR and QDMTT Application
On January 30, 2026, Japan’s National Tax Agency issued a law implementation circular clarifying certain aspects of its UTPR and QDMTT.
Canada Issues Instructions for Filing Pillar 2 Returns
In January 2026, Canada issued the filing procedures for the GIR, GMT Return and the Double Filing Relief Notification.
Korea Issues Amendments to its Enforcement Decree for Pillar 2 Updates
On January 19, 2026, South Korea issued a Draft Law to amend the Enforcement Decree to the International Tax Adjustment Act. This provides for detailed provisions for the application of the QDMTT and will also extend the Transitional CbCR Safe Harbour by 1 year (as provided in the January 2026 OECD Side-by-Side Package).
Hong Kong Opens its Pillar 2 E-Filing Portal
On January 19, 2026, the Hong Kong Inland Revenue Department opened its E-filing portal for the submission of Top-Up Tax Notifications
Israel Enacts its DMTT Law with Significant Changes from the Previous Draft law
On December 31, 2025, Israel enacted Law No. Law 5776-2025 on the Minimum Corporate Tax for Multinational Groups. The enacted law contains some significant changes from the previous draft law.
