
New Zealand Implements OECD Side-by-Side Tax Package With a Timing Amendment
A review of the remedial timing amendment that aligns New Zealand’s GloBE incorporation rules with the OECD’s January 2026 Side-by-Side Package.

A review of the remedial timing amendment that aligns New Zealand’s GloBE incorporation rules with the OECD’s January 2026 Side-by-Side Package.

On April 17, 2026, the Brazil opened up a consultation on proposed changes to its QDMTT regime to implement the Substance-based Tax Incentives (SBTI) Safe Harbour.

On 9 and 10 April 2026, the Dutch Tax Administration’s Pillar Two Knowledge Group published two administrative positions on the treatment of joint ventures under the Dutch Minimum Tax Act 2024.

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

A guide to South Africa’s current public Pillar Two compliance package: eFiling subscription for Global Minimum Tax, the six‑month information / notification step, the GloBE Information Return (GIR), and the South Africa‑specific XML rules that sit on top of the OECD GIR structure

A practical guide to Hong Kong’s Registration, top-up tax notification, GIR / top-up tax return architecture, and current Hong Kong-specific data-format rules

A practical guide to Germany’s Registration, group head notification and GloBE Information Return (GIR) filing through the BZSt framework

Australia issued the Taxation (Multinational—Global and Domestic Minimum Tax) (Qualified GloBE Taxes) Amendment (Measures No. 1) Determination 2026, on March 20, 2026. This updates Australia’s domestic lists of foreign Qualified IIRs, foreign Qualified Domestic Minimum Top-up Taxes, and jurisdictions with QDMTT Safe Harbour status

On March 24, 2026, Finland gazetted a law amending its Minimum Tax Act to provide for aspects of the January 2026 OECD Side By Side Tax Package and the June 2024 and January 2025 OECD Administrative Guidance.
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