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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Australia’s November exposure draft proposes annual Side-by-Side and UPE safe harbours from 2026, while preserving domestic minimum tax. Consultation closes on 26 November.
Brazil’s Federal Revenue Service has published draft rules to add a Simplified ETR Safe Harbour to the Additional CSLL from fiscal years beginning on or after 1 January 2027. The consultation closes on 16 November 2026.
Liechtenstein’s Parliament passed amendments replacing the time-limited Article 28 safe-harbour power and adding Government competence for the GIR MCAA list. The measure awaits the referendum and Gazette stages.
Poland’s Parliament has passed a bill that would raise ordinary corporate income tax to 22% for taxpayers that were in scope of Poland’s Pillar Two law in the preceding year, as an alternative to a EUR 50 million local-revenue trigger. The bill awaits presidential action and does not amend Poland’s IIR, UTPR or QDMTT rules.
Ireland Revenue eBrief No. 164/26 adds operational rules for correcting and deleting accepted Top-up Tax Information Returns and for coding the jurisdictions entitled to receive centrally filed GIR data. The 15- and 18-month filing deadlines are unchanged.
AADE Decisions A.1236 and A.1237, published on 2 November 2026, prescribe separate domestic top-up tax and IIR/UTPR self-assessment returns. The decisions address designated filers, nil returns, electronic submission and payment under Greece’s existing Pillar Two regime.
Royal Decree 101/2026, published in Gazette 1672 on 1 November 2026, rewrites Oman’s Pillar Two registration, filing and payment provisions. Specified amendments apply from the tax year beginning 1 January 2025; the additional enforcement provisions take effect on 2 November 2026.
Curaçao’s final minimum-tax ordinance introduces an IIR from fiscal years beginning in 2025, reserves domestic-tax and UTPR chapters, and sets separate GIR and tax-return deadlines.
Italy’s Revenue Agency rejects using lower 2023 comparatives restated under OIC 34 for the 2024 Pillar Two scope test. We examine Response No. 188/2026 and the implications for groups near the €750 million threshold.
Uruguay’s signed IMCD decree dated 16 October 2026 adds previously missing GloBE elections and develops the rules for income, covered taxes, foreign-tax allocation, negative tax expense and transition years. It also provides detailed safe harbours and designated-filer obligations. This analysis explains the changes against the existing DMTT law.
Switzerland adopts a one-year delay to the OECD Article 9.1 DTA guidance for 2024, with foreign IIR and grace-period cap implications.
The OECD’s October 2026 GIR XML guide incorporates the revised reporting framework and sets a June 2028 transition for exchanges, including corrections to earlier returns.
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