December 31, 2025: The Netherlands
Part III of the Dutch Year-End Decree 2025 (published in the Official Gazette on December 23, 2025) amends the Minimum Tax Executive Decree 2024 for aspects of the December 2023, June 2024, and January 2025 OECD Administrative Guidance:
https://zoek.officielebekendmakingen.nl/stb-2025-451.html
December 31, 2025: Singapore
On December 30, 2025, IRAS issued further details on the Pillar 2 registration process. The registration portal is to be open from May 2026, however, a draft registration form and explanatory notes have been issued. NB there is also a requirement to disclose companies incorporated or registered in Singapore that had shifted their tax residency from Singapore to a foreign jurisdiction after November 30, 2021.
IRAS | Registration for Multinational Enterprise Top-up Tax and Domestic Top-up Tax
December 30, 2025: Thailand
On December 29, 2025, the Thai Cabinet approved 4 draft laws/regulations on the implementation of the Pillar 2 rules in Thailand. The laws need to be published in the Official Gazette. The laws are:
Draft Royal Decree on the criteria for considering liability to additional tax for groups of multinational legal entities undergoing corporate restructuring, together with an explanatory note (principles and rationale) and a summary analytical note.
Draft Royal Decree prescribing legal entities that are not related legal entities, together with an explanatory note (principles and rationale) and a summary analytical note.
Draft Ministerial Regulation, issued under the Executive Decree on Top-Up Tax, B.E. 2567 (2024), on the allocation of residual additional tax received by Thailand to related legal entities established in Thailand, together with an explanatory note (principles and rationale) and a summary analytical note.
Draft Ministerial Regulation, issued under the Executive Decree on Top-Up Tax, B.E. 2567 (2024), on adjustments to income, expenses and taxes within scope for the calculation of additional tax, together with an explanatory note (principles and rationale) and a summary analytical note.
December 27, 2025: Liechtenstein
On December 23, 2025, Liechtenstein published the Act of November 7, 2025 amending the GloBE Act to provide for the GIR MCAA and amended registration provisions:
2025.588 | Lilex – Legal database of the Principality of Liechtenstein
December 27, 2025: Liechtenstein
On December 23, 2025, Liechtenstein published an amendment to its GloBE Regulation to provide for a list of jurisdictions that apply for the purposes of the GIR information exchange purposes:
2025.598 | Lilex – Legal database of the Principality of Liechtenstein
December 27, 2025: Turkey
On December 26, 2025, Turkey published the Communique for the detailed application of the IIR. UTPR and QDMTT in its Official Gazette:
https://www.gib.gov.tr/mevzuat/kanun/435/teblig/11843
December 27, 2025: Finland
On December 19, 2025, the Finnish Official Gazette issued Decision No. 1249/2025, on the GLoBE tax information return filing, including DAC9 implementation:
December 23, 2025: Denmark
On December 19, 2025, the Danish Official Gazette published an Executive Order providing for GIR information reporting requirements:
https://www.lovtidende.dk/api/pdf/254001
December 23, 2025: Denmark
On December 17, 2025, the Danish Official Gazette published Law No. 1643 to amend the Minimum Tax Act for the GIR filing/DAC9, QDMTT Design and changes to payment:
https://www.lovtidende.dk/api/pdf/253865
December 23, 2025: Ireland
On December 18, 2025, the Irish Revenue issued Revenue eBrief No. 244/25 which provides for an extension in the Pillar 2 registration deadline to February 28, 2026 (from December 31, 2025):
December 22, 2025: Luxembourg
On December 19, 2025, the Luxembourg Official Gazette published:
-a law to amend its Minimum Tax Law to provide for the January 2025 OECD Administrative Guidance and to transpose the EU DAC9 Directive into domestic law; and
-a Grand Ducal Regulation to provide for the model GIR:
Law of 19 December 2025 on the exchange of… – Legilux
Grand-Ducal Regulation of 19 December 2025 establishing the … – Legilux
December 22, 2025: South Africa
On December 19, 2025, SARS released further guidance on the Pillar 2 Registration process:
Global Minimum Tax | South African Revenue Service
December 19, 2025: Vietnam
Vietnam has issued a Draft Decree to provide that the QDMTT will be deemed to be zero for enterprises implementing power plant projects under the Build-Operate-Transfer (BOT) mechanism provided that the contract has a tax commitment and is signed before the effective date of Resolution 107/2023/QH15 (January 1, 2024):
December 19, 2025: Portugal
Order No. 158/2025 XXV issued on December 12, 2025 provides that for constituent entities whose fiscal year ended between December 31, 2024 and March 31, 2025 the filing deadline for Form 62 (the Pillar 2 Registration Form) is the last day of the 15th month following the end of that fiscal year:
Despacho_SEAF_158_2025_XXV_12dez.pdf
December 18, 2025: Australia
On December 17, 2025, Australia issued updated guidance on the application of Pillar 2 including the treatment of consolidated groups, misaligned fiscal years and prior period adjustments:
Specific issues for Pillar Two | Australian Taxation Office
December 17, 2025: The Netherlands
On December 16, 2025, the Dutch Parliament passed a law to amend the Minimum Tax Act for the June 2024 and January 2025 OECD Administrative Guidance:
December 17, 2025: Hungary
The Law to exchange information under the OECD GIR MCAA was published in the Official Gazette on December 16, 2025:
December 17, 2025: France
On December 9, 2025, France released its GIR (based on the OECD template) and updated its User Guide.
December 15, 2025: San Marino
On December 11, San Marino deposited its instrument of ratification for the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (the STTR Convention):
December 11, 2025: Thailand
On December 4, 2025, the Thai Revenue Department issued Notification No’s 4 and 5 on the determination of employees and tangible assets for the purpose of the Substance-Based Income Exclusion:
December 10, 2025: Sweden
On December 10, 2025, Sweden gazetted amendments to its Global Minimum Tax Act to implement the OECDs June 2024 Administrative Guidance:
December 10, 2025: Slovenia
On December 4, 2025, the Slovenian Official Gazette published Law No. 3396, amending the Tax Procedure Act. Articles 29 and 40 of the amendment law include provisions to introduce the Pillar 2 EU information exchange provisions in DAC 9:
Vsebina Uradnega lista | Uradni list
December 9, 2025: Finland
On November 25, 2025, the Finnish Tax Administration published guidance on the allocation of profits/losses and taxes between group entities to take account of the June 2024 OECD Administrative Guidance:
December 8, 2025: France
On December 3, 2025, France updated its Pillar 2 Guidance to include guidance on
-the procedures for taking into account deferred taxes and assets transferred in respect of the transition year and subsequent years;
– the temporary exemption for groups in their initial phase of international activity:
BOI-IMG-TRANS – IMG – Transitional rules | bofip.impots.gouv.fr
December 8, 2025: Thailand
On 18 November 2025, Thailand’s Ministry of Finance issued notification no. 1 under Minimum Tax Law to provide for the Transitional SBIE rates:
December 4, 2025: Australia
On November 26, 2025, the ATO updated its Pillar Two website guidance to include:
-a sample combined global and domestic minimum tax return for a Group Entity
-a sample combined global and domestic minimum tax return for a designated local entity (DLE):
https://www.ato.gov.au/api/public/content/51265412a86544219f67c18b92bf4ea5?v=2251e173
https://www.ato.gov.au/api/public/content/07a1b078b2e345939ec300ef2c2bae4f?v=b14bae74
December 4, 2025: Sweden
On December 3, 2025, the Swedish Parliament adopted the amendment to the Pillar 2 Law. The amendments primarily relate to the June 2024 OECD Administrative Guidance:
December 2, 2025: Montenegro
On November 26, 2025, Montenegro issued a Draft Law to apply the Pillar 2 GloBE rules from January 1, 2026. This includes just a QDMTT (the IIR and UTPR are not being implemented).
Nacrt Zakona o globalnom minimalnom porezu na dobit pravnih lica
December 2, 2025: Turkey
On December 1, 2025, Turkey announced:
– an extension in the filing and payment date for the QDMTT return for the 2024 tax period from December 31, 2025 to January 15, 2026; and
– the opening of a test environment for the submission of the QDMTT return:
Circular – Revenue Administration
November 28, 2025: UK
On November 26, 2025, the UK issued a Policy Paper with further planned amendments to its Minimum Tax Law. These include:
adjustments to provisions that set out how pre-regime deferred tax assets should be treated
technical amendments to the clawback provisions that apply to tax equity partnerships
simplified calculations for non-material members
changes to the rules allowing the profits of a flow-through ultimate parent entity to be reduced
adjustments to the election to exclude intra-group transactions
adjustments to the recognition of payments for group relief as a covered tax for Domestic Top-up Tax
technical adjustments to the test of whether de-merged groups meet the revenue threshold
technical adjustments to the application of Part 3 to permanent establishments
adjustments to the method for converting Domestic Top-up Tax amounts into sterling
changes to the test of whether an instrument is to be regarded as equity or debt
a provision under Multinational Top-up Tax which disapplies another jurisdictions’ Qualified Domestic Minimum Top-up Tax safe harbour where the Qualified Domestic Minimum Top-up Tax does not apply to securitisation vehicles
a provision which ensures no liability under the undertaxed profits rule can be applied to a securitisation vehicle
a provision which removes profits and losses relating to Real Estate Investment Trusts from adjusted profits for the purposes of Domestic Top-up Tax
a provision for certain overseas undertaxed profits taxes to have qualifying status in the UK prior to the making of UK regulations and ahead of the outcomes of the ongoing process for international agreement on qualification of undertaxed profits taxes
technical adjustments to cater for foreign Qualified Income Inclusion Rules and Qualified Domestic Minimum Top-up Taxes whose application is subject to an election or claim
technical adjustments to clarify the location of a stateless entity
technical adjustments to resolve double counting in relation to tax transparent investment entities
technical adjustments to the cross-border allocation of deferred tax
technical adjustments to the allocation of CFC mobile income
technical adjustments to clarify the meaning of underlying profits and underlying profits accounts
other minor amendments and corrections
Pillar 2: Further amendments to Multinational Top-up Tax and Domestic Top-up Tax – GOV.UK
November 27, 2025: Switzerland
On November 26, 2025, the Swiss Federal Council approved an amendment to the Swiss Minimum Tax Ordinance to provide for the OECD provisions relating to the submission of GloBE Information Returns, including the guidance issued in January 2025:
November 20, 2025: Hungary
On November 19, 2025, Hungary gazetted Law No. 2025 LXXXIII to enact the changes to the Transitional CbCR Safe Harbour as proposed in the 2025 Autumn Tax Package:
November 20, 2025: Slovakia
On November 18, 2025, Slovakia issued its QDMTT Return:
November 17, 2025: Belgium
On November 17, 2025, the Belgian tax authorities officially confirmed that the deadline for filing the QDMTT returns for reporting years:
– beginning on December 31, 2023 or later, and
– ending on June 30, 2025 at the latest,
is extended until June 30, 2026.
November 17, 2025: Hungary
On November 14, 2025, Hungary issued a Draft Regulation (for consultation) to provide for the detailed application of the Pillar 2 Safe Harbours:
A globális minimumadó mentességek részletes szabályairól szóló miniszteri rend.
November 14, 2025: Guernsey
Guernsey has opened its Pillar 2 Registration Portal, to appoint the Domestic Filing Entity and register Domestic Constituent Entities:
Pillar Two – States of Guernsey
November 11, 2025: Italy
Italy has issued 2 regulations relating to the Administration of the Pillar 2 top-up tax.
The November 7, 2025 Decree of the Deputy Minister of Economy and Finance provides for more information on the rules for the annual GloBE tax return that must be submitted to the Revenue Agency, and for the payment of top-up tax due in Italy.
Resolution no. 63 of 10 November 2025 provides for the tax codes to be used for the payment of top-up tax on the F24 payment form.
November 10, 2025: Finland
On November 3, 2025, Finland issued a draft law for consultation to amend its Minimum Tax Act for the June 2024 and January 2025 OECD Administrative Guidance:
This follows a draft law issued in October to implement the EU DAC 9 provisions:
Government proposal VM/2025/156 – Government
November 10, 2025: Romania
On November 7, 2025, Romania issued the Draft Order for the model and content of the GIR and the double filing relief notification:
https://static.anaf.ro/static/33/Anaf/20251107114534_07nov-proiect.zip
November 10, 2025: Liechtenstein
On November 5, 2025, Liechtenstein’s Parliament approved an act for the amendment of Liechtenstein’s Global Minimum Tax Act. The bill is intended to implement domestically the OECD provisions for the exchange of information in the GloBE Information Return (GIR) under the Multilateral Competent Authority Agreement on the Exchange of GloBE Information:
November 8, 2025: Singapore
On October 14, 2025, the Finance (Income Taxes) Bill 2025 was published. This includes a number of amendments to the Global Minimum Tax provisions for the June 2024 OECD Administrative Guidance:
Finance (Income Taxes) Bill – Singapore Statutes Online
November 6, 2025: Mauritius
A Communique of October 29, 2025 issued by the MRA provides that:
– The QDMTT applies to a resident company forming part of an in-scope multinational enterprise group with a fiscal year ending on or after 1 January 2025
– The deadlines for QDMTT notifications that are already due, have been extended to 30 November 2025
– The online portal for making a QDMTT notification is now open:
November 4, 2025: Kenya
On November 3, 2025, Kenya issued the Draft Income Tax (Minimum Top Up Tax) Regulations, 2025 to provide for the detailed application of the Pillar 2 DMTT:
November 4, 2025: Thailand
On October 21, 2025, the Thai Revenue Department issued three Notifications that address (1) the definition of Acceptable Accounting Standards, (2) the definition of refundable dividend taxes not within the scope of covered taxes, and (3) the definition of flow-through entities and the location rules:
ประกาศอธิบดีกรมสรรพากร | กรมสรรพากร – The Revenue Department (rd.go.th)
November 4, 2025: Italy
On 30 October 2025, the Finance Department of the Ministry of Economy and Finance published Guidance on the submission of the GIR. This follows the Decree of October 16, 2025 that included the format of the GIR and DAC 9 implementation:
Direttiva-interpretativa-GIR_.pdf
Department of Finance – Decree of 16 October 2025 of the Deputy Minister of Economy and Finance
November 3, 2025: Ireland
On October 16, 2025, Ireland published its 2025 Finance Bill. This includes amendments for the January 2025 OECD Administrative Guidance, DAC 9 implementation as well as other technical amendments:
October 30, 2025: South Africa
On October 28, 2025, Government Notice No. 6763 was issued which extended some of the Pillar 2 filing and notification deadlines:
October 29, 2025: Spain
On October 29, 2025, Order HAC/1198/2025, of October 21 was published in the Official Gazette. This approves the final versions of three specific Pillar 2 forms – Form 240 (registration), Form 241 (the GIR) and Form 242 (the top-up tax return).
Disposición 21727 del BOE núm. 260 de 2025
October 27, 2025: Australia
On October 26, 2025, Australia opened a consultation on minor changes to the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024 for the OECD’s Administrative Guidance:
International taxation – global and domestic minimum tax – amending legislation – Consult hub
October 23, 2025: Slovakia
On October 21, 2025, Slovakia’s Parliament approved a Law to amend its Minimum Tax Act to provide for the June 2024 and January 2025 OECD Administrative Guidance, as well as EU DAC 9 Directive amendments:
Zákony : Vyhľadávanie v návrhoch zákonov : Detaily návrhu zákona – Národná rada Slovenskej republiky
October 23, 2025: Italy
Italy issued Decree of October 16, 2025 which provides for the format of the GIR, the method of submission and exchange (updated for the January 2025 OECD Administrative Guidance) as well as the EU DAC 9 information exchange provisions:
Department of Finance – Decree of 16 October 2025 of the Deputy Minister of Economy and Finance
October 23, 2025: Belgium
On October 22, 2025, Belgium issued Circular 2025/C/68 which provides detailed guidance on the application of the Pillar 2 rules in Belgium:
October 22, 2025: Hungary
On 21 October, 2025 the Form 24GLBADO for the Advance QDMTT Tax Declaration was published on the ONYA platform and is available for submission:
October 22, 2025: Vietnam
On October 21, 2025, Vietnam released Decision 3563/QD-BTC 2025 on the Administrative Procedures for the Minimum Tax. This includes the final forms to be submitted for notification, registration and returns:
Decision 3563/QD-BTC 2025 announcing new administrative procedures in tax administration
October 21, 2025: Guernsey
Guernsey has issued the Guernsey Pillar 2 Brief: Issue 1 which includes further detail on the registration process (the actual registration system is planned to be operational during the fourth quarter of 2025):
October 20, 2025: Austria
On October 16, 2025 Austria issued a draft law to amend the Minimum Tax Act for the December 2023, June 2024 and January 2025 OECD Administrative Guidance:
October 17, 2025: France
On October 14, 2025, France released the 2026 Finance Bill. This includes amendments to include the June 2024 OECD Administrative Guidance, as well as DAC 9 implementation:
Exercice 2026 | budget.gouv.fr
October 17, 2025: France
On October 9, 2025, France issued its first set of Guidance on the Pillar 2 rules (definitions, scope, excluded entities and territoriality):
BOI-IMG – IMG – Imposition mondiale des groupes | bofip.impots.gouv.fr
October 17, 2025: Hungary
On October 2, 2025, Hungary released the 2025 Autumn Tax Package. This includes some amendments to the operation of the Transitional CbCR Safe Harbour:
4932661ce0811bbf2b9e0b929accd30b2ed43127.pdf
October 16, 2025: Hungary
On October 15, 2025, Hungary issued the draft Advance QDMTT Tax Declaration (Form 24GLBADO) as well as filing instructions and a draft XML guide.
October 16, 2025: UK
On October 15, 2025, the UK updated its list of qualifying jurisdictions for the IIR, QDMTT and the QDMTT Safe Harbour:
Notice 2 — Pillar Two top-up taxes relevant territories and taxes – GOV.UK
October 15, 2025: Belgium
On October 10, 2025, Belgium issued a Draft Law to amend its Minimum Tax Act. There are a number of technical amendments (which don’t effect the Minimum Tax calculation) as well as administrative amendments:
October 7, 2025: Brazil
On October 3, 2025 Normative Instruction RFB No. 2282, of October 2, 2025 was published in the Official Gazette. This includes amendments to Brazil’s QDMTT Law for the OECD June 2024 and January 2025 OECD Administrative Guidance:
October 6, 2025: Israel
On October 5, 2025, Israel published a draft law for consultation for a QDMTT from 2026:
October 3, 2025: Turkey
On October 3, 2025, Turkey published the Draft Communique on the Minimum Tax Law, and the Draft GIR, for consultation.
Whilst Turkey has enacted its Minimum Tax Law, a lot of the detailed application of the GloBE rules was left to a further Regulation. This Communique therefore provides for the detailed rules for the implementation of the GloBE rules in Turkey.
Draft Communique on the Minimum Tax Law
October 3, 2025: Croatia
On September 18, 2025, Croatia opened a consultation on a Draft Bill to amend its Minimum Tax Act. The amendments are primarily to amend the QDMTT accounting standard so that the Croatian QDMTT qualifies for the QDMTT Safe Harbour and to provide for the notification deadline for appointing a designated filing entity:
October 2, 2025: OECD
On September 30, 2025, the OECD issued an updated list of signatories to the GIR MCAA to include Germany, Liechtenstein and Norway:
October 1, 2025: Hong Kong
On September 26, 2025, Hong Kong updated its Pillar 2 guidance to include information on its Pillar 2 Portal, applications for Group Codes and mandatory e-filing of profit tax returns for Pillar 2 groups:
IRD : Global minimum tax and Hong Kong minimum top-up tax for multinational enterprise groups
September 30, 2025: Germany
On September 29, 2025, the Federal Ministry of Finance opened a consultation on a draft regulation for the implementation of the Minimum Tax Act. This provides for compliance rules for the exchange of the GIR and simplified reporting:
Verordnung zur Durchführung des Mindeststeuergesetzes (Mindeststeuerverordnung – MinStV)
September 17, 2025: The Netherlands
On September 16, 2025, The Netherlands Cabinet issued a Draft Bill for the Second Amendment to the Minimum Tax Act to implement the June 2024 and January 2025 OECD Administrative Guidance (as well as the EU DAC 9 proposals):
Wetsvoorstel-Tweede-wet-aanpassing-wet-minimumbelasting-2024.pdf
September 17, 2025: Japan
Japan has launched its Multinational Enterprise Information Reporting Portal for filing Pillar 2 returns.
Forms are filed via the Japanese E-Tax System in the Multinational Enterprise Information Reporting Portal. Returns related to global minimum tax for the fiscal year starting after April 1, 2024, are accepted from September 16, 2025:
September 12, 2025: Switzerland
On September 12, 2025, the Swiss Federal Council issued the Federal Decree on the Approval of the Multilateral Agreement of the Competent Authorities on the Exchange of Global Anti-Base Erosion Declarations, which ratifies the OECD GIR MCAA:
September 12, 2025: Poland
On September 11, 2025, the Polish Ministry of Finance issued the draft Pillar 2 notifications and top-up tax returns for consultation:
September 11, 2025: Ireland
On September 8, 2025, Ireland released Revenue eBrief No. 170/25 with detailed information on the registration process:
September 9, 2025: Vietnam
On September 8, 2025, the Ministry of Finance announced it is to issue a draft resolution to amend its global minimum tax law to exempt from the QDMTT entities implementing BOT power projects with a Government Guarantee:
September 4, 2025: Portugal
On September 2, 2025, Portugal issued Ordinance No. 290/2025/1 which includes the format for the Pillar 2 registration form (Form 62):
September 3, 2025: Czech Republic
On September 2, 2025, Act No. 316/2025 Coll was published in the Official Gazette to amend the Minimum Tax Act for various aspects of the OECD Administrative Guidance:
September 2, 2025: Uruguay
On August 31, 2025, the Ministry of Economy and Finance sent the Draft Budget Law for the period 2025–2029 to Parliament. This includes a domestic minimum tax (intended to be a QDMTT).
Proyecto de Ley de Presupuesto Nacional 2025-2029.pdf
September 1, 2025: Vietnam
On August 29, 2025, Vietnam issued Decree 236/2025/ND-CP providing for the detailed provisions for the application of the Pillar 2 Global Minimum Tax rules in Vietnam:
Decree 236/2025/ND-CP: Detailing Resolution 107/2023/QH15 on additional corporate income tax
September 1, 2025: Brazil
On August 29, 2025, Brazil issued proposed amendments to its QDMTT Law for consultation to take account of the June 2024 and January 2025 OECD Administrative Guidance and other sundry amendments:
September 1, 2025: Malta
Malta has announced it is to repeal its Article 50 postponement of the EU Minimum Tax Directive and apply the Pillar 2 rules. Further details are to be announced in the Budget:
Malta to implement 15% minimum tax for multi-national companies
August 29, 2025: Romania
On August 29, 2025, Ordinance No. 21 of August 28, 2025 was published in the Official Gazette. This amends various aspects of the Minimum Tax Act, including for the filing deadline for the designated filing entity nomination, transferable tax credits and the excess negative tax carry forward election.
August 29, 2025: Australia
On August 26, 2025, the Taxation (Multinational—Global and Domestic Minimum Tax) (Qualified GloBE Taxes) Determination 2025 was issued. This provides for a list of jurisdictions that have qualified status for the purposes of the income inclusion rule (IIR) and domestic minimum tax (DMTT), including the QDMTT Safe Harbour.
August 27, 2025: Australia
On August 27, 2025, the Australian Taxation Office issued a draft legislative instrument for consultation (the ‘Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR tax return and Australian DMT tax return) Determination 2025’). This outlines situations when entities within the scope of the Pillar 2 GloBE rules do not need to file an Australian DMT Return or an IIR/UTPR Return:
August 22, 2025: Romania
On August 20, 2025, the Romanian government issued a draft law. The law proposes amendments to various aspects of the Minimum Tax Act, including for the local accounting standard and local currency for QDMTT purposes, transferable tax credits and the excess negative tax carry forward election:
August 21, 2025: Slovakia
On August 20, 2025, the Slovakian Government issued a draft law to implement the OECD June 2024 and January 2025 OECD Administrative Guidance:
https://oecdpillars.com/wp-content/uploads/2025/08/SKDraft.pdf
August 20, 2025: Mauritius
The Finance Act 2025, enacted on August 8, 2025, includes a new QDMTT from July 1, 2025:
August 20, 2025: OECD
On August 18, 2025, the OECD updated the list of jurisdictions with Transitional Qualifying Status:
Central Record of Legislation with Transitional Qualified Status | OECD
August 19. 2025: Sweden
On August 14, 2025, the Swedish Government published a draft law to amend its Global Minimum Tax Act. This follows a previous proposal issued on March 20, 2025.
August 18, 2025: Germany
On August 5, 2025, Germany’s Ministry of Finance issued a letter providing for the XML for the GIR including instructions on how to file electronically.
August 18, 2025: Canada
On August 13, 2025, Canada issued draft legislative proposals to amend its Global Minimum Tax Act to provide for aspects of the June 2024 and January 2025 OECD Administrative Guidance:
Legislative Proposals Relating to the Global Minimum Tax Act
August 18, 2025: Italy
On August 7, 2025, Italy issued its designated entity notification form for GIR filing:
Designated Entity – GIR Form Instructions
August 12, 2025: Romania
On August 11, 2025, Romania issued form N408 to nominate a designated filing/payment entity for QDMTT purposes.
August 11, 2025: Germany
On August 6, 2025, Germany issued the draft bill to amend the Minimum Tax Act. This follows the two previous discussion drafts and now includes the January 2025 OECD Administrative Guidance and DAC9 amendments:
August 7, 2025: OECD
On August 6, 2025, the OECD published the current signatories to the GIR MCAA Framework:
August 6, 2025: Korea
Koreas 2025 Tax Reform Proposal (announced on July 31, 2025), provides that a QDMTT will be applied from January 1, 2026:
2025년 세제개편안 발표 | 보도·참고자료 | 기획재정부
August 4, 2025: OECD
On 30 July 2025, the OECD/G20 Inclusive Framework on BEPS released a GloBE Information Return (GIR) Status Message XML Schema for Pillar Two:
GloBE Information Return (Pillar Two) Status Message XML Schema | OECD
August 4, 2025: Luxembourg
On July 24, 2025, the Luxembourg Government issued:
– a draft law to amend its Minimum Tax Law to provide for the January 2025 OECD Administrative Guidance and the EU DAC 9 GIR filing requirements: and
– a draft Regulation which includes the format of the GIR
eli-dl-pr-2025-221-doc-dprgd-1-fr-pdf.pdf
July 31, 2025: Kuwait
On July 16, 2025, Kuwait updated its electronic registration portal to include GMT registration:
https://www.mof.gov.kw/TCRS_Public
July 28, 2025: UK
On July 24, 2025, the UK issued a notice to amend the Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025 (SI 2025/406) to include Spain and Guernsey as jurisdictions qualifying for GloBE purposes (QIIR, QDMTT and the QDMTT Safe Harbour).
Notice 2 — Pillar Two top-up taxes relevant territories and taxes – GOV.UK
July 24, 2025: UK
On July 21, 2025, the UK issued draft legislation for the January 2025 OECD Administrative Guidance and other relevant changes. This includes:
-adjustments to provisions that set out how pre-regime deferred tax assets should be treated
-technical amendments to the clawback provisions that apply to tax equity partnerships
-simplified calculations for non-material members
-changes to the rules allowing the profits of a flow through ultimate parent entity to be reduced
-adjustments to the election to exclude intragroup transactions
-adjustments to the way Domestic Top-up Tax is allocated
-technical adjustments to the test of whether de-merged groups meet the revenue threshold
-technical adjustments to the application of Part 3 to permanent establishments
-adjustments to method of converting Domestic Top-up Tax amounts into sterling
-changes to the test of whether an instrument is to be regarded as equity or debt
-other minor amendments and corrections
July 16, 2025: Australia
On July 16, 2025, the ATO released a Draft Practical Compliance Guideline
on the transitional approach to filing obligations for the IIR,UTPR and QDMTT:
July 11, 2025: Romania
On July 9, 2025, ANAF Order 1.729/2025 was issued to nominate a single designated entity for QDMTT filing and payment purposes, if there are several constituent entities in Romania that are part of the same group.
ORDER 1729 01/07/2025 – Legislative Portal
July 9, 2025: Bahrain
On July 2, 2025, Bahrain issued its Advance Payments Manual for details on the procedures for estimating and remitting advance DMTT liabilities:
الجهاز الوطني للإيرادات – دليل سداد الدفعات المعجلة لضريبة الحد الأدنى الإضافية
July 8, 2025: Japan
On June 30, 2025, Japan issued its updated GIR to reflect the OECD GIR changes in January 2025:
June 30, 2025: Kuwait
On June 29, 2025, Kuwait issued Ministerial Resolution No. 55 of 2025 to provide for the Executive Regulations for the QDMTT:
June 30, 2025: US
On June 28, 2025, the G7 announced agreement on a ‘side-by-side’ system to exempt U.S. parented groups from the Income Inclusion Rule and Undertaxed Profits Rule:
G7 statement on global minimum taxes – Canada.ca
June 27, 2025: Belgium
On June 24, 2025, Belgium issued the draft XSD for the QDMTT return.
June 26, 2025: Hungary
On June 19, 2025, the 2025 Spring Tax Package was published in the Official Gazette.
June 25, 2025: Isle of Man
On June 19, 2025, the updated version of the Global Minimum Tax (Pillar Two) Order 2024 was published.
Global Minimum Tax (Pillar Two) Order 2024
June 20, 2025: Romania
On June 20, 2025, a draft Order was issued to nominate a single designated entity for QDMTT filing and payment purposes, if there are several constituent entities in Romania that are part of the same group:
https://static.anaf.ro/static/33/Anaf/20250620131647_detalii_proiect.zip
June 20, 2025: Slovakia
On June 16, 2025, Slovakia issued a draft law to amend its minimum tax act to provide for the June 2024 and January 2025 OECD Administrative Guidance, as well as EU Directive DAC 9 amendments.
Legislatívny proces – LP/2025/310
June 17, 2025: Norway
On June 16, 2025, Norway’s Ministry of Finance opened a consultation on a draft Bill to amend its Minimum Tax Law to implement the OECD’s June 2024 and January 2025 Administrative Guidance:
Høyring – implementering av administrativ rettleiing i suppleringsskattelova – regjeringen.no
June 12, 2025: Spain
On June 3, 2025, the Spanish State Tax Agency issued the draft Pillar 2 forms for consultation.
Open procedures: Hearing and public information: Ministry of Finance
Spain Issues Draft Pillar 2 Forms for Registration, GIR and the Top-Up Tax Return – oecdpillars.com
June 11, 2025: Iceland
On June 5, 2025, Iceland opened a consultation on a draft bill to implement an IIR and QDMTT under the OECD Pillar 2 GloBE rules.
Consultation portal | Case: S-101/2025
Iceland Issues a Draft Bill for IIR and Domestic Top-Up Tax From January 1, 2026 – oecdpillars.com
June 10, 2025: Mauritius
In the 2025 Budget speech delivered on June 5, 2025, Mauritius proposed a Domestic minimum top-up tax (DMTT) effective for income derived on or after July 1, 2025.
June 6, 2025: Denmark
On June 3, 2025, Bill 2024/1 LSV 194 A to amend the Danish Minimum Tax Act for the June 2024 and January 2025 OECD Administrative Guidance was passed by Parliament.
https://www.retsinformation.dk/eli/ft/202413LA0194
June 6, 2025: Hong Kong
The Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025 has been published in the Official Gazette. The law is now enacted.
Hong Kong e-Legislation – e-Gazette List
Hong Kong Enacts Law for IIR and Domestic Top-Up Tax From January 1, 2025 – oecdpillars.com
May 29, 2025: Kenya
Section 7 of the 2025 Finance Bill (sent to Parliament on May 7, 2025), provides that the DMTT is payable by the end of the fourth month following the end of the fiscal year.
May 28, 2025: Hong Kong
The Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024 was passed by the Legislative Council on May 28, 2025. It now needs to be signed by the Chief Executive and published in the Official Gazette.
news.gov.hk – Bill on Minimum Tax for Multinational Enterprises Passed
May 20, 2025: Hungary
On May 13, 2025, Bill T/11920 was issued (the 2025 Spring Tax Package). This includes a provision to amend the Pillar 2 registration deadline to 2 months after the end of the relevant tax year.
May 16, 2025: Australia
On May 15, 2025, Australia issued updated guidance on the application of Pillar 2, including
-guidance about how to administer potential amendments to Australian law to address inconsistencies
-an overview of the mechanics for calculating top-up tax
-additional information on how the rules apply, including in respect of specific entities,
-additional information and examples about lodgement, payment and record keeping obligations,
-how Pillar Two interacts with other provisions and how it applies.
Global and domestic minimum tax | Australian Taxation Office
May 16, 2025: Bahrain
On May 15, 2025, Bahrain issued Guidance on Administrative Requirements for the DMTT, including Registration, Elections and Payment of tax:
National Bureau of Revenue – Guidelines for Administrative Procedures for Minimum Additional Tax
May 16, 2025: Ireland
On May 8, 2025, Ireland issued Revenue eBrief No. 098/25 for further updates to its Guidance on Pillar Two Administration:
May 12, 2025: OECD
On May 9, 2025, the OECD released the 2025 Consolidated Commentary to the GloBE rules. This includes updates for the June 2024 and 2025 OECD Administrative Guidance:
May 9, 2025: Spain
On April 29, 2025, Spain published Law No. 3/2025 of 29 April 2025 in the Official Gazette, which modifies the Economic Agreement with the Basque Country, originally approved in 2002. Among other things, modifications are made to adapt the agreement to Law No. 7/2024 of 20 December 2024 for the implementation of the Pillar 2 global minimum tax in accordance with Council Directive (EU) 2022/2523 of 14 December 2022.
May 7, 2025: EU
On May 6, 2025, the EU DAC 9 Directive was published in the Official Journal of the European Union. The Directive enters into force on May 7, 2025. Member States will have to adopt and publish the laws, regulations and administrative provisions necessary to comply with the directive by December 31, 2025.
Directive – EU – 2025/872 – EN – EUR-Lex
May 1, 2025: Switzerland
On April 30, 2025, the Swiss Federal Council issued a proposal to the update the Swiss Minimum Tax Ordinance to provide for the OECD provisions relating to the submission of GloBE Information Returns, including the guidance issued in January 2025. The amended Ordinance also updates the application of the OECD Administrative Guidance applied in Switzerland to include the January 2025 OECD Administrative Guidance and the use of the 2023 Consolidated Commentary.
April 25, 2025: Hong Kong
In April 2025, the Hong Kong Government proposed a number of Committee Stage Amendments to the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024. This includes amendments for the January 2025 OECD Administrative Guidance:
April 24, 2025: Isle of Man
On April 24, 2025, the Online Service was launched. This is currently limited to registration and adding group details. Filing returns is not yet supported. Guidance note 64 provides details of the service.
GN64 – Pillar 2 Online Service Guide
April 24, 2025: Malta
On April 17, 2025, Act No. IX of 2025 was published in the Official Gazette. This includes a new Section 22B in the Income Tax Act to provide that rules will be issued to provide for an elective tax (likely to give Pillar Two in-scope companies the option to subject their profits to the elective tax in Malta to ensure that no top-up tax is due elsewhere).
April 17, 2025: UAE
On April 16, 2025, the Ministry of Finance issued Ministerial Decision No. (88) of 2025 to provide for the application of the OECD Administrative Guidance from January 1, 2025:
English-Ministerial-Decision-No.-88-of-2025-on-Commentary-and-Guidance-for-Top-Up-Tax.pdf
UAE Issues Ministerial Decision to Implement the OECD Administrative Guidance – oecdpillars.com
April 16, 2025: The Bahamas
On February 26, 2025, the Bahamas Government issued the Domestic Minimum Top-Up Tax (Amendment) Bill, 2025 to provide that business license fees are creditable for DMTT purposes. This was approved by the Senate in April 2025.
DOMESTIC MINIMUM TOP-UP TAX (AMENDMENT) BILL, 2025
April 16, 2025: Poland
On April 7, 2025, the Polish Ministry of Finance released details for a draft bill to amend the Minimum Tax Act. The amendments are to implement the June 2024 and January 2025 OECD Administrative Guidance:
April 15, 2025: EU
On April 14, 2025, the Council of the EU approved the DAC 9 Directive. It simplifies reporting for large corporations by enabling central filing a top-up tax information return (TTIR) and introduces a standard form for filing the TTIR across the EU, in line with the GIR.
Member states will have to adopt and publish, by 31 December 2025, the laws, regulations and administrative provisions necessary to comply with the directive. The first top-up tax reporting is due by 30 June 2026.
Countries opting to delay the implementation of the Pillar 2 Directive are still required to transpose DAC 9 by the same deadline.
April 12, 2025: South Korea
South Korea’s Decree No. 35348 of February 28, 2025 amending the Enforcement Decree to the International Tax Adjustment Act and the Decree of the Ministry of Economy and Finance No. 1114 of March 21, 2025 amending the Enforcement Regulations to the International Tax Adjustment Act provide for further aspects of the June 2024 OECD Administrative Guidance as well as additional Pillar 2 top-up tax forms:
April 11, 2025: OECD
On March 31, 2025, the OECD issued updated Administrative Guidance that includes a list of jurisdictions that have transitional qualified status for the purposes of the income inclusion rule (IIR) and domestic minimum tax (DMTT), including the QDMTT Safe Harbour :
April 10, 2025: Belgium
On April 10, 2025, Belgium’s Ministry of Finance released the QDMTT Return. This is still considered in draft form until it has been published in the Official Gazette:
April 8, 2025: Japan
On March 31, 2025, the amendment laws to implement the UTPR and QDMTT in Japan from April 1, 2026 were published in the Official Gazette:
April 7, 2025: Germany
On April 3, 2025, the German Tax Authority issued a letter on the treatment of fiscally transparent partnerships (such as domestic or foreign partnerships that are not subject to corporate income tax) for CbCR purposes and for the purposes of the Pillar 2 Transitional CbCR Safe Harbour.
April 3, 2025: Finland
On March 10, 2025 and March 12, 2025, Finland issued explanatory guidance on the application of the Minimum Tax Act, including provisions from the OECD June 2024 Administrative Guidance relating to the DTL recapture:
Minimum taxation of large groups – vero.fi
Minimum taxation of large groups – Taxes to consider – vero.fi
April 2, 2025: Spain
On April 2, 2025, Spain issued Royal Decree 252/2025 to approve the Regulations for the Global Minimum Tax. The Regulations include a number of aspects of the OECD Administrative Guidance.
April 2, 2025: UK
On March 31, 2025, the UK issued the The Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025.
This provides:
– a list of each territory that is a ‘Pillar 2 territory’ under section 241 Finance (No.2) Act 2023, reflecting its implementation of a qualifying income inclusion rule,
– a list of each tax that is a qualifying domestic top-up tax under section 256 Finance (No.2) Act 2023 (and the respective territories of those taxes),
– a list of each tax specified as being accredited for the qualifying domestic top-up tax safe harbour in Schedule 16A to Finance (No.2) Act 2023 (and the respective territories of those taxes).
April 1, 2025: Qatar
On March 27, 2025, Law No. 22 of 2024 amending certain provisions of Income Tax Law No. (24) of 2018 was published in Qatar’s Official Gazette. This implements the Pillar Two Income Inclusion Rule (IIR) and a Domestic Minimum Top- Up Tax (DMTT which is intended to be a Qualified Domestic Minimum Top-Up Tax) from January 1, 2025.
Qatar Enacts a Pillar Two Income Inclusion Rule and Domestic Minimum Tax – oecdpillars.com
March 27, 2025: Bulgaria
On March 27, 2025, Bulgaria’s 2025 State Budget Law (the ‘2025 Budget Law’) was published in the Official Gazette. This includes a number of changes to the Corporate Income Tax Law to amend the Global Minimum Tax provisions from January 1, 2024.
March 24, 2025: UK
On March 20, 2025, the Finance Act 2025 received Royal Assent. This includes Pillar 2 changes to implement the UTPR from December 31, 2024, as well as other changes to implement the June 2024 OECD Administrative Guidance.
March 20, 2025: Sweden
On March 20, 2025, Sweden issued proposed amendments to its Global Minimum Tax Act for consultation. The amendments are primarily to implement the OECDs June 2024 Administrative Guidance.
Ytterligare kompletteringar till bestäm¬melserna om tilläggsskatt för företag i stora koncerner
March 20, 2025: Germany
On March 11, 2025, Germany announced an update to its Group Leader Notification form:
Amtliches Vordruckmuster für die Gruppenträgermeldung
March 19, 2025: Liechtenstein
On March 18, 2025, the government approved a draft bill on the amendment of Liechtenstein’s Global Minimum Tax Act (‘the bill’).
The bill is intended to implement domestically the OECD provisions for the exchange of information in the GloBE Information Return (GIR) under the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA).
March 17, 2025: Italy
On March 6, 2025 a Decree of the Italian Ministry of Finance on Notification for Global Minimum Tax purposes was published in the Official Gazette (the ‘March Ministerial Decree’).
This provides more details on the double filing relief notification under Article 51(4) of Legislative Decree December 27, 2023, no. 209 (the Global Minimum Tax Law), and as provided in Article 8.1.3 of the OECD Model Rules.
http://www.gazzettaufficiale.biz/atti/2025/20250054/25A01340.htm
Italy Issues Decree for Double Filing Relief Notification Under the Pillar 2 Rules – oecdpillars.com
March 14, 2025: Bulgaria
On February 18, 2025, updated draft legislation to amend the corporate income tax act for changes to the Pillar 2 global minimum tax rules were issued:
March 10, 2025: UAE
On March 4, 2025, the UAE Ministry of Finance issued updated FAQs on the DMTT, including the expectation that it will be listed as a QDMTT in the OECD peer review process and the general operation of the DMTT in the UAE:
UAE Domestic Minimum Top-up Tax – Ministry of Finance – United Arab Emirates
March 4, 2025: Denmark
On February 18, 2025, the Executive Order on registration requirements was published in the Official Gazette.
Section 2 of the Order states that the information to be provided will be:
1) Name and address.
2) CVR number. If the group entity does not have a CVR number, the SE number must be provided
3) From which date the group entity is covered by the Minimum Taxation Act.
March 3, 2025: Gibraltar
On February 20, 2025, Gibraltar issued the Income Tax (Allowances, Deductions, and Exemptions) (Amendment) Rules 2025.
This provides that a Gibraltar Parent Entity that is within scope of the provisions of the Income Tax Act 2010 and the Global Minimum Tax Act 2024 can elect that the provisions of the Income Tax Act 2010 that levy a charge to tax will not apply to the Gibraltar Parent Entity or the Constituent Entities of that Group and only the Global Minimum Tax Act 2024 will apply.
Under Section 3 of the Rules, a “Gibraltar Parent Entity” is defined as:
-a Constituent Entity of a Group that is ordinarily resident in Gibraltar under the Income Tax Act 2010; or
-an Ultimate Parent Entity registered or otherwise established in Gibraltar.
The terms “Constituent Entity”, “Group” and “Ultimate Parent Entity” have the meanings given in the Global Minimum Tax Act 2024 or the OECD Model Rules.
Given that Gibraltar’s corporate income tax rate under Income Tax Act 2010 is 15%, this is designed as a simplification measure to allow MNEs to be taxed under a single regime.
The election must be made in writing and approved by the tax authority. Once approval is given the election, it applies for accounting periods commencing after the date the election is made. If the MNE group subsequently falls out of scope of the Pillar 2 rules, this must be notified to the Tax Authority.
February 17, 2025: France
On February 15, 2025, the French Finance Act 2025 was published in the Official Gazette. Article 53 includes amendments to the French Global Minimum Tax Regime for the OECD Administrative Guidance.
LAW No. 2025-127 of 14 February 2025 on Finance for 2025 (1) – Légifrance
February 13, 2025: Poland
On February 12, 2025, the Polish Minster of Finance published in the Official Gazette a list of jurisdictions that have qualified status for the purposes of the income inclusion rule (IIR) and domestic minimum tax (DMTT), including the QDMTT Safe Harbour.
February 10, 2024: Romania
On February 7, 2025, Order no. 193 of 2025 was published in the Official Gazette. This provides amendments to the income tax return (form 100) to report amounts due under the IIR/UTPR or DMTT.
https://legislatie.just.ro/Public/DetaliiDocument/294623
February 10, 2024: UAE
On February 8, 2025, the Ministry of Finance announced the issue of Cabinet Resolution 142 of 2024 for the detailed provisions for the application of the DMTT.
https://oecdpillars.com/wp-content/uploads/2025/02/UAE_Cabinet_Decision.pdf
GloBE Country Guide: The UAE – oecdpillars.com
February 7, 2025: Japan
On February 4, 2025, Japan submitted the draft tax reform bill for 2025 to Parliament. This includes a QDMTT and UTPR from April 1, 2026.
February 6, 2025: Denmark
On February 3, 2025, the Danish Ministry of Finance issued draft legislation (Bill 2024-4606) for consultation. This is to amend the Danish Minimum Tax Act for the June 2024 and January 2025 OECD Administrative Guidance.
Forslag til lov om ændring af minimumsbeskatningsloven m.v. (høring).pdf
January 31, 2025: Japan
On January 28, 2025, the National Tax Agency revised the “Q&A on the Global Minimum Tax” for determining whether laws and regulations relating to the QDMTT Safe Harbour meet the requirements of the QDMTT accounting standard and consistency standard.
January 29, 2025: UK
On January 28, 2025, the UK issued further draft guidance for the application of the GloBE rules (MTT and DTT) in the UK. This is open for consultation until April 8,2025.
Multinational Top-up Tax and Domestic Top-up Tax: Supplementary draft guidance – GOV.UK
On January 27, 2025, the UK made further amendments to the Finance Bill 2024-2025 for various technical changes relating to the application of the GloBE rules.
Finance Bill 2024-25: Public Bill Committee – GOV.UK
January 28, 2025: France
France has released its Pillar 2 notification form for in-scope groups (Form N° 2065-INT-SD 2025).
Article 223 WW(1) of the law provides that a constituent entity located in France that is a member of an in-scope MNE or domestic group is required to confirm to the tax administration in its income statement its membership in the group. It must also indicate the identity of the ultimate parent entity of the group and, where applicable, the entity filing the GIR as well as the jurisdiction in which they are located.
The notification form is filed as an annex to the tax return.
January 21, 2025: USA
On January 20, 2025, the White House issued a memorandum that instructs the Treasury Secretary to notify the OECD that any commitments made by the prior Administration with respect to the ‘Global Tax Deal’ have no force or effect within the United States absent an act by Congress adopting the relevant provisions of the Global Tax Deal.
In addition, the memorandum directs the Treasury Secretary in consultation with the United States Trade Representative to investigate whether any foreign countries are not in compliance with any tax treaty with the United States or have any tax rules in place, or are likely to put tax rules in place, that are extraterritorial or disproportionately affect American companies, and develop and present to President Trump within 60 days a list of options for protective measures or other actions that the United States may adopt or take in response to such non-compliance or tax rules:
January 16, 2025: Indonesia
On December 31, 2024 the Ministry of Finance issued Minister of Finance Regulation Number 136 of 2024 regarding the imposition of a global minimum tax which will take effect from January 1, 2025.
January 15, 2025: OECD
On January 15, 2025, the OECD issued further publications/guidance covering three areas:
1) A list of jurisdictions that have transitional qualified status for the purposes of the income inclusion rule and domestic minimum tax;
2) Further Administrative Guidance on the application of the Article 9.1 transitional rules, primarily in relation to deferred tax assets (DTAs) arising from tax benefits provided by General Government after November 30, 2021; and
3) An updated GloBE Information Return (GIR) and GIR XML Schema, as well as the GIR Multilateral Competent Authority Agreement, (MCAA) which outlines the conditions and operation for the automatic exchange of GIR information and further Administrative Guidance on the data that MNE Groups will rely on to complete the GIR (Articles 8.1.4 and 8.1.5 of the OECD Model Rules).
January 13, 2025: South Africa
On January 9, 2025, the Global Minimum Tax Administration Act 47 of 2024 was published to provide for the administrative provisions for the Global Minimum Tax provisions in South Africa.
January 13, 2025: North Macedonia
On January 3 2025 the Law on Global Minimum Corporate Income Tax was published in the Official Gazette. This applies the IIR and a DMTT from January 1, 2024 and the UTPR from January 1, 2025.
January 13, 2025: South Korea
On December 31, 2024, Law No. 20612, was published to amend the Global Minimum Tax Act for the 2025 Tax Reform provisions.
January 10, 2025: Liechtenstein
On January 9, 2025, Luxembourg released its GloBE Registration form (submitted via email within 6 months of the end of the fiscal year).
Global Minimum Taxation of large MNE Groups
January 9, 2025: Italy
On December 31, 2024, Ministerial Decree of December 27, 2024 was published in the Official Gazette. This implements the OECD Administrative Guidance on the treatment of deferred taxation generated in the period prior to the implementation of the GloBE rules.
This follows another Ministerial Decree published in the Official Gazette on December 30, 2024 (Ministerial Decree of December 20, 2024) which addressed miscellaneous aspects of the GloBE Rules/Administrative Guidance (including the Forex Hedge election, debt release election and sovereign wealth funds).
Gazette no. 304 of 30 December 2024 – MINISTRY OF ECONOMY AND FINANCE
January 6, 2024: Gibraltar
The Global Minimum Tax Act 2024 was enacted on December 23, 2024.
The Act includes a Domestic Top-up Tax that first applies to Fiscal Years beginning on or after December 31, 2023 and an Income Inclusion Rule that applies to Fiscal Years commencing on or after December 31, 2024.
January 2, 2025: Oman
On December 31, 2024, Oman issued Royal Decree No. 70/2024 that promulgates the Global Minimum Tax Law on entities affiliated to multinational groups. It is to be published in the Official Gazette on Sunday at which point the attachments to the Decree (which contain the provisions of the GMT Law) will be available. It comes into force on January 1, 2025:
January 2, 2025: Singapore
On December 30, 2024, Singapore published the Multinational Enterprise (Minimum Tax) Regulations 2024 which provide for the detailed rules for the application of the multinational top-up tax (MTT) and domestic top-up tax (DTT).
6a67444b-aa17-481e-adc7-4ea07c504b46 1..128
January 2, 2025: Brazil
On December 30, 2024, Brazil’s President enacted Law No. 15,079, of December 27, 2024, that repeats (with minor amendments) Provisional Measure No. 1,262, of October 3, 2024, to introduce a Domestic Minimum Tax from January 1, 2025.
LAW NO. 15,079, OF DECEMBER 27, 2024 – LAW NO. 15,079, OF DECEMBER 27, 2024 – DOU – National Press
On December 31, 2024, Normative Instruction No. 2245, of December 30, 2024 was issued which implements the detailed regulations for the provisions of the domestic minimum tax as provided in Normative Instruction No. 2,228, of October 3, 2024, with a number of amendments.
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