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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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.
On March 17, 2026, Belgium issued a Circular on Pillar Two Currency Conversion.
On March 19, 2026, Belgium issued a Consultation on the Pillar 2 IIR Top-Up Tax Return.
On March 19, 2026, Switzerland opened up its GIR Filing Portal. Download our Swiss GIR Filing Checklist.
On March 19, 2026, Switzerland opened up its GIR Filing Portal.
On March 10, 2026, Montenegro published its law to implement a global minimum tax (QDMTT) in its Official Gazette.
On March 17, 2026, Spain’s Navarra region published Decree 13/2026, of February 25. 2026 in its Official Gazette. This approves the Global Minimum Tax Regulations for the Navarra Region and applies to tax periods beginning on or after December 31, 2023
On March 12, 2026, Australia updated its guidance on Lodging, paying and other obligations for Pillar Two.
On March 10, 2026, Liechtenstein issued a proposal (for consultation) to amend its Minimum Tax Act to enable it to implement the January 2026 OECD Side-by-Side Tax Package.
On February 12, 2026, Finland issued a draft law to implement the OECD Side By Side Tax Package. On March 3, 2026 this was approved by the Parliamentary Finance Committee.
On February 16, 2026, Australia issued the Taxation (Multinational—Global and Domestic Minimum Tax)
Amendment (2026 Measures No.1) Rules 2026, to amend its Global Minimum Tax Rules.
On February 13, 2026, Poland issued a draft law to amend its Global Minimum Tax Law for the December 2023, June 2024 and January 2025 OECD Administrative Guidance. This also includes QDMTT changes, including the introduction of a Local Financial Accounting Standard rule.
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