
Australia proposes Side-by-Side safe harbours and DTL recapture amendments
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.

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.
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