Global Minimum Tax
In Today’s 2023 Budget, Hong Kong’s Financial Secretary confirmed that Hong Kong will implement the Pillar Two Global Minimum Tax from 2025.
They estimate that it will generate tax revenue of $15 billion per year for the Government. A consultation is to be launched to allow MNE groups to make early preparation.
It was also announced that Hong Kong will be introducing a Patent Box.
Given the significant foreign direct investment (FDI) into Hong Kong (in 2021 FDI inflows into Hong Kong were US$140.7 billion, the 3rd highest globally behind the United States and Mainland China), it is expected that there will be other ancillary adjustments over the next 2 years to the domestic tax regime to ensure Hong Kong remains internationally competitive after the GloBE rules are introduced.
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On October 29, 2025, Order HAC/1198/2025, of October 21 was published in the Official Gazette. This approves the final versions of three specific Pillar 2 forms – Form 240 (registration), Form 241 (the GIR) and Form 242 (the top-up tax return).
On October 21, 2025, Slovakia’s Parliament approved a law to amend its minimum tax act to provide for the June 2024 and January 2025 OECD Administrative Guidance, as well as EU Directive DAC 9 amendments.
On October 21, 2025, Vietnam released Decision 3563/QD-BTC 2025 on the Administrative Procedures for the Minimum Tax. This includes the final forms to be submitted for notification, registration and returns.
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).
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.
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.
On October 2, 2025, Hungary released the 2025 Autumn Tax Package. This includes some amendments to the operation of the Transitional CbCR Safe Harbour.
On October 15, 2025, Hungary issued the draft Advance QDMTT Tax Declaration (Form 24GLBADO) as well as filing instructions and a draft XML guide.
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.
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.
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.
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.
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