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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France’s government tabled amendment I-3734 to the 2027 Finance Bill on 10 October 2026. It proposes Side-by-Side and UPE safe harbours, a one-year Transitional CbCR Safe Harbour extension and related payment and implementation changes. The proposal remains subject to parliamentary processing and enactment.
Montenegro’s Rulebook in Official Gazette 143/2026 entered into force on 9 October 2026. It prescribes Form PIDP, XML filing, a pre-deadline filer notice, central-filing relief and local fallback/exchange procedures.
Singapore’s Parliament passed Bill 22/2026 on 6 October 2026. The Bill advances Side-by-Side safe-harbour powers, GIR exchange and local fallback filing, return-exemption powers, and DTT accounting rules, but still awaits assent and publication.
Thailand is consulting until 5 November 2026 on legislative principles for a Revenue Department QRTC framework, including electronic certificates, tax settlement, refunds and transfers. The proposal leaves eligibility, rates and commencement to further legislation and rules.
A Belgian Chamber committee has unanimously approved a bill implementing DAC9, establishing the domestic framework for centralised GIR exchange and extending the statutory QDMTT return deadline from 11 to 15 months, with an 18-month transitional rule.
Norway’s 2027 budget proposition proposes separate statutory powers for the Pillar Two safe harbours, together with commencement provisions and technical corrections. Most Top-up Tax Act amendments would apply to financial years beginning after 31 December 2025.
Cyprus has tabled a Pillar Two amendment bill to introduce a qualified domestic minimum top-up tax for financial years beginning from 31 December 2025.
On 18 September 2026, Brazil issued IN RFB No. 2,342/2026 to introduce a new framework for the treatment of substance-based tax incentives under its Pillar Two rules.
On 15 September 2026, the Dutch government presented a bill that would introduce four new Pillar Two safe harbours, extend the Transitional Country-by-Country Reporting Safe Harbour and amend the treatment of certain 52- and 53-week accounting periods.
On September 11, 2026, the OECD released a package of guidance and implementation materials that provides for the exclusion of Explicitly Conditional Taxes from Covered Taxes, clarifies the treatment of mismatched fiscal periods under the Qualified Domestic Minimum Top-up Tax Safe Harbour, updates the GloBE Information Return and establishes the detailed framework for full legislative reviews of domestic minimum tax rules.
Uruguay’s presidential decree dated 31 August 2026 replaces the conditional QDMTT payment waiver in Decree No. 325/025 with a compensation mechanism. Article 1 requires in-scope constituent entities allocated QDMTT in Uruguay to comply with its QDMTT obligations and pay the tax; article 7 repeals the earlier decree.
Qatar has published six decisions dealing with currency conversion, simplified reporting, the Transitional CbCR Safe Harbour, non-material constituent entities, designated local entities and registration.
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