The Director of International Taxation of the Directorate General of Taxes has confirmed Indonesia is planning to implement the Pillar Two GloBE Rules from 2024.
This is unlike Singapore which has delayed the implementation until 2025.
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On 6 September 2025, Nigeria’s Tax Act 2025 was published in the Official Gazette. This includes a DMTT (without any of the detailed GloBE adjustments yet applying).
On September 11, 2025, the Polish Ministry of Finance issued the draft Pillar 2 notifications and top-up tax returns for consultation.
On August 29, 2025, Vietnam issued its Decree for the detailed implementation of the Pillar 2 rules from January 1, 2024.
On September 2, 2025, Portugal issued Ordinance No. 290/2025/1 which includes the format for the Pillar 2 registration form (Form 62).
On September 2, 2025, Act No. 316/2025 Coll was published in the Official Gazette to amend the Minimum Tax Act for various aspects of the OECD Administrative Guidance as well as filing dates, QDMTT amendments and amending the Safe Harbour rules.
On August 31, 2025, the Ministry of Economy and Finance sent the Draft Budget Law for the period 2025–2029 to Parliament. This includes a domestic minimum tax (intended to be a QDMTT).
On August 29, 2025, Brazil issued proposed amendments to Normative Instruction No. 2,228 for consultation to take account of the June 2024 and January 2025 OECD Administrative Guidance and other sundry amendments.
On August 29, 2025, Ordinance No. 21 of August 28, 2025 was published in the Official Gazette. This amends various aspects of the Minimum Tax Act, including for the filing deadline for the designated filing entity nomination, transferable tax credits and the excess negative tax carry forward election.
On August 26, 2025, Australia issued a list of jurisdictions that have qualified status for the purposes of the income inclusion rule and domestic minimum tax (including the QDMTT Safe Harbour).
On August 27, 2025, the Australian Taxation Office issued a draft legislative instrument (the ‘Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR tax return and Australian DMT tax return) Determination 2025’). This outlines situations when entities within the scope of the Pillar 2 GloBE rules do not need to file an Australian DMT Return or an IIR/UTPR Return.
The Finance Act 2025, enacted on August 8, 2025, introduces a new Sub-Part AF to the Income Tax Act to include a domestic minimum top-up tax (intended to be a QDMTT) from July 1, 2025.
On January 15, 2025, the OECD issued Administrative Guidance that includes a list of jurisdictions that have transitional qualified status for the purposes of the income inclusion rule and domestic minimum tax (including the QDMTT Safe Harbour). This was subsequently updated on March 31, 2025 and August 18, 2025.
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