Guernsey Issues Guidance on Pillar 2 Registration
Guernsey has issued the Guernsey Pillar 2 Brief: Issue 1 which includes further detail on the registration process (the actual registration system is planned to be operational during the fourth quarter of 2025).
France Releases 2026 Finance Bill with Amendments for June 2024 OECD Administrative Guidance
On October 14, 2025, France released the 2026 Finance Bill. This includes amendments to include the June 2024 OECD Administrative Guidance, as well as DAC 9 implementation.
Hungary Issues the Draft Advance QDMTT Return
On October 15, 2025, Hungary issued the draft Advance QDMTT Tax Declaration (Form 24GLBADO) as well as filing instructions and a draft XML guide.
Belgium Issues a Draft Law for Pillar 2 Amendments
On October 10, 2025, Belgium issued a Draft Law to amend its Minimum Tax Act. There are a number of technical amendments (which don’t effect the Minimum Tax calculation), the correction of an error in the original text as well as administrative amendments.
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.
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.
