
Canada Issues Instructions for Filing Pillar 2 Returns
In January 2026, Canada issued the filing procedures for the GIR, GMT Return and the Double Filing Relief Notification.

In January 2026, Canada issued the filing procedures for the GIR, GMT Return and the Double Filing Relief Notification.

On January 19, 2026, South Korea issued a Draft Law to amend the Enforcement Decree to the International Tax Adjustment Act. This provides for detailed provisions for the application of the QDMTT and will also extend the Transitional CbCR Safe Harbour by 1 year (as provided in the January 2026 OECD Side-by-Side Package).

On January 19, 2026, the Hong Kong Inland Revenue Department opened its E-filing portal for the submission of Top-Up Tax Notifications

On December 31, 2025, Israel enacted Law No. Law 5776-2025 on the Minimum Corporate Tax for Multinational Groups. The enacted law contains some significant changes from the previous draft law.

On December 29, 2025, Uruguay’s President issued Decree No. 325/025, to provide for exemptions from the QDMTT for entities covered by a tax stability agreement. Note that Law N° 20446 to enact the QDMTT was published in the Official Gazette on January 8, 2026.

On December 23, 2025, Korea enacted Law number 21215 to implement the 2026 Tax Reform. This includes a QDMTT from January 1, 2026.
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