GloBE Country Guide: Denmark
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Denmark for accounting periods beginning on or after 31 December, 2023. Updated for the final law enacted on December 12, 2023 and the Draft Law of April 30, 2024.
Luxembourg Enacts a Law to Implement January 2025 OECD Administrative Guidance and EU DAC 9
On December 19, 2025, the Luxembourg Official Gazette published:
– a law to amend its Minimum Tax Law to provide for the January 2025 OECD Administrative Guidance and the EU DAC 9 GIR filing requirements: and
– a Grand Ducal Regulation which includes the format of the GIR
South Africa Issues Update on Pillar 2 Registration
On December 19, 2025, SARS issued further guidance on the Pillar 2 registration process.
Portugal Extends its Pillar 2 Registration Deadline
Order No. 158/2025 XXV issued on December 12, 2025 provides that for constituent entities whose fiscal year ended between December 31, 2024 and March 31, 2025 the filing deadline for Form 62 (the Pillar 2 Registration Form) is the last day of the 15th month following the end of that fiscal year.
The Netherlands Approves its Pillar 2 Amendment Law for the OECD Administrative Guidance
On December 16, 2025, The Netherlands Parliament approved the Second Amendment to the Minimum Tax Act to implement the December 2023, June 2024 and January 2025 OECD Administrative Guidance.
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.
