Paraguay stands out amongst most South American countries as being the one most at risk of substantial jurisdictional top-up tax for in-scope groups under Pillar Two.
Its standard rate of corporate income tax is 10% under Article 21 of Law No. 6,380/19 on the Modernization and Simplification of the National Tax System. This is in contrast to other South American jurisdictions that have much higher standard rates of corporate income tax, such as:
Brazil – 34%
Argentina – 35%
Chile – 27%
Peru – 29.5%
Columbia – 35%
Venezuela – 34%
Guyana – 40%
Mexico – 30%
Nicaragua – 30%
Ecuador – 25%
Bolivia – 25%
Uruguay – 25%
Article 1 of Law No. 6,380/19 on the Modernization and Simplification of the National Tax System establishes a territorial basis for corporate income tax in Paraguay. As such, only income from Paraguayan sources is taxable, subject to a number of exceptions. For instance, Article 6 of Law 6,380/19 provides that Paraguayan source income includes:
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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
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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.
On March 24, 2026, Belgium issued an updated draft QDMTT Form and XSD Schema.
A practical guide to Luxembourg’s top-up tax return on MyGuichet.lu, including what the local XML does, which fields drive the filing logic, and where groups usually need extra controls.
On February 27, 2026, South Korea issued an amendment to its international tax adjustment decree to provide for detailed provisions for the application of its QDMTT.
In this article we look at how Japan handles the Pillar Two GloBE Information Return through the e-Tax Multinational Enterprise Information Reporting Corner, what fields Japan localises in the GIR XML and CSV package, and how that sits alongside the Japanese top-up tax return.
View our downloadable checklist for Japan’s Pillar Two filing process.
On March 17, 2026, Belgium issued a Circular on Pillar Two Currency Conversion.
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