In Bermuda’s 2023 Budget last week, the government has announced it is actively looking at how to implement the Pillar Two global minimum tax and that Bermuda could reap significant revenue benefits.
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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.
On December 29, 2025, Uruguay’s President issued Decree No. 325/025, to provide for exemptions from the QDMTT for entities covered by a tax stability agreement. Note that Law N° 20446 to enact the QDMTT was published in the Official Gazette on January 8, 2026.
On December 23, 2025, Korea enacted Law number 21215 to implement the 2026 Tax Reform. This includes a QDMTT from January 1, 2026.
On January 5, 2026, the OECD Released Guidance on amendments to the Pillar 2 rules for the Side-by-Side Tax Package. This includes a new Simplified ETR Safe Harbour from December 31, 2026 (December 31, 2025 in certain cases). We provide an excel overview and a sample calculator for the key elements of the Safe Harbour calculation.
On January 5, 2026, the OECD Released Guidance on amendments to the Pillar 2 rules for the Side-by-Side Tax Package. This includes a new Substance-based Tax Incentive Safe Harbour. This online tool shows how the new safe harbour operates.
On January 5, 2026, the OECD Released Guidance on amendments to the Pillar 2 rules for the Side-by-Side Tax Package. This article looks at a number of the new elections that arise from this.
On January 5, 2026, the OECD Released Guidance on amendments to the Pillar 2 rules for the Side-by-Side Tax Package.
On December 23, 2025, Germany enacted a law to amend the Minimum Tax Act. This follows the two previous discussion drafts and now includes the January 2025 OECD Administrative Guidance and DAC9 amendments.
On December 23, 2025, Austria published the Tax Amendment Act 2025 in its Official Gazette. This includes amendments to aspects of the December 2023, June 2024 and January 2025 OECD Administrative Guidance, as well as DAC 9 implementation.
Part III of the Dutch Year-End Decree 2025 (published in the Official Gazette on December 23, 2025) amends the Minimum Tax Executive Decree 2024 for aspects of the December 2023, June 2024, and January 2025 OECD Administrative Guidance.
On December 30, 2025, IRAS issued further details on the Pillar 2 registration process. The registration portal is to be open from May 2026, however, a draft registration form and explanatory notes have been issued.
On December 26, 2025, Turkey published the Communique on the Minimum Tax Law. 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.
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