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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A guide to Italy’s three-track Pillar Two process: the reporting-entity notification, the DAC9/GIR (Comunicazione Rilevante), and the domestic GloBE Return (Dichiarazione fiscale Globe) with related F24 payments.
A guide to Australia’s Pillar Two filing. It covers the separate local GIR XML filing, the foreign lodgement notification, and the Combined Global and Domestic Minimum Tax Return (CGDMTR), including the Australian IIR/UTPR tax return and Australian DMT tax return. It also flags the main ATO validation rules and the software / API points that matter if you are building or testing a filing process.
A guide to Spain’s three-part Pillar Two workflow: model 240 (group/filing notification), model 241 (GIR-DAC9 information return), and model 242 (top-up tax self-assessment).
On April 7, the Swiss Federal Tax Administration issued Communication-031-E-2026-f and Communication-030-E-2026-f to apply the OECD January 2025 and January 2026 Administrative Guidance
On April 8, 2026, Germany issued a Draft Regulation which included a list of jurisdictions with qualifying status for the purposes of the IIR, UTPR, QDMTT and the QDMTT Safe Harbour.
On April 8, 2026, the Turkish Revenue Administration published draft versions of its Pillar Two Tax Returns/Notifications.
On April 3, 2026, Liechtenstein enacted an amendment to its Pillar Two Regulation (LGBl. 2026 Nr. 114). This includes amendments to the Pillar Two regime including providing for aspects of the January 2026 Side-by-Side tax package.
A guide to Vietnam’s Pillar Two compliance flow: the reporting-entity notification, special tax registration, the GIR information package embedded in the Vietnamese filing package, and the QDMTT and IIR return packages filed through the tax e-filing system.
This guide focuses on Austria’s GIR filing architecture as published by the Austrian Federal Ministry of Finance (BMF): access to FinanzOnline, filing channels, the Austrian national XML overlay on top of the OECD GIR, correction mechanics, and transport/protocol handling for implementation.
On March 31, 2026, Japan enacted its 2026 Tax Reform Package. This includes amendments to the Pillar Two regime including providing for aspects of the January 2026 Side-by-Side tax package (excluding the Simplified ETR Safe Harbour) and the January 2025 OECD Administrative Guidance.
On March 25, 2026, Australia issued the Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2026 Measures No. 1) Rules 2026, to amend its Pillar Two rules to incorporate aspects of the OECD Administrative Guidance for DMTT purposes.
On March 25, 2026, Sweden issued a draft law to include new Pillar Two simplification rules including the Side-by-Side Safe Harbour, UPE Safe Harbour, and other additions to Sweden’s top-up tax rules
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