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| Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | Section/Article | |||||
| First Set of OECD Administrative Guidance | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
| 1.1 | Rebasing monetary thresholds in the GloBE Rules | 1-25(3) Regs | July 2024 Amendment Law – 79a | Transposed | 73, Regs | 8(3) | – | March 2025 Budget law,various | Normative Reg 2(5)/11(3)/(4) | 7 | – | – | 36 | – | FA2025, Art 53, (28) | 97 | Yes – Transposed | – | Yes – Transposed | Generally transposed | 2 | 42 – draft bill | Transposed under Section 7 | 51, Regs | 111AAAA | 20 December 2024 Decree, Article 9 | 38-3 Ordinance | Transposed | Art 112, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Regulation to be issued | – | No AG included | December Amending law, 1.4 | Transposed by Section HP3 of the ITA | Section 1-4, law | 2(4) | 53 | 2(3) | 9, law, Regs 5, 8,9 | 45 | 101 (Enforcement Decree) | All AG Transposed | ch 1, 4 | Transposed – Article 2 | 2(3)/(4) | 2.1.1 Communique | 10 | 254 | ||||||||||||
| 1.2 | Deemed consolidation test | 13- Excludes State Entities | July 2024 Amendment law 2(1) – excludes state entities from the defn of entity | Transposed | 1(1)- Excludes State Entities | 2 – Excludes the state | – | – | Normative Reg 9(para 3) – excludes state entities | 4- Excludes State Entities | – | 1.2 – excludes state entities | 2, Excludes state entities | – | – | Ch. 1,4/19 (Amendment law) – excludes state entities | – | 4(6) -Excludes State Entities | Yes – Transposed | – | Yes – Transposed | Note to 10.1.1 | – | Transposed under Section 7 | Excludes State Entities | Appendix A (13) – Excludes State Entities | 2024 Amendments, Art 82 – Excludes State Entities | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | – | – | 1.2 – Excludes State Entities | Transposed by Section HP3 of the ITA | 1-5-1 Regs – Excludes State Entities | – | – | – | – | All AG Transposed | Ch. 2 ,6 /5a | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | 231 – Excludes State Entities | App II, (4) excludes the state | ||||||||||||||||
| 1.3 | Consolidated deferred tax amounts | 4_85 Regs | – | Transposed | – | – | – | – | – | – | – | – | 15 | Yes – Transposed | – | Yes – Transposed | Note to 4.4.1 | Yes | Transposed under Section 7 | Transposed under general interpretative provision | – | – | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | 22 | – | – | Transposed by Section HP3 of the ITA | – | – | law, First schedule, 3 – exc state entities | amending law, Art 1,1 exclude state entities | – | All AG Transposed | Amending law, 14 | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | 134/182 | |||||||||||||||||||||
| 1.4 | Sovereign wealth funds and the definition of Ultimate Parent Entity | 13(3) of the Assessment Act] | 2(14) | Transposed | 1(1) | – | March 2025 Budget Law, S1, additional provisions (132) | Normative Instruction Art 3 | 12 | – | 1.2(6) | 2 nb excludes the National Investment Fund from the UPE defn | 2025 law 6(5) | 4(14)(a) | Ch. 1,19 (amending law) | October 2025 Guidance | 4(3) | Yes – Transposed | – | Yes – Transposed | Note to 1.4 | – | Transposed under Section 7 | Transposed under general interpretative provision | 20 December 2024 Decree, Article 2 | 2024 Amendments, Art 82 – Excludes State Entities | Transposed | Art 6, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Art 1 | 5.4 of the Govt guidance | 1.2 | Transposed by Section HP3 of the ITA | 1-5-1 Regs | – | 2(2) law | Amending law, Art 1,8 | 61(1)(6) Law | All AG Transposed | Article 5(14) | December 2024 Amending law Chapter 2, sections 14 and 32 | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | Section 4 | 2.2.4.1 Communique | 1.6 | 252 | App II, (5.4) | |||||||||||||
| 1.5 | Clarifying the definition of ‘Excluded Entity’ | 1_20 Regs | 4(1) | Transposed | – | – | Normative Instruction Art 3 | – | – | 2 | – | – | October 2025 Guidance | – | Yes – Transposed | – | Yes – Transposed | Note to 1.5.2 | – | Transposed under Section 7 | Transposed under general interpretative provision | – | – | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | – | – | – | Transposed by Section HP3 of the ITA | 1-3-1 Regs | 5(8) | – | – | – | – | All AG Transposed | – | Transposed – Article 2 | 3.1/3.2 Communique | 1.8 | 127 | ||||||||||||||||||||
| 1.6 | Meaning of ancillary for Non-Profit Organisations | 1-20 Regs | 4(1) | Transposed | – | – | Normative Reg 22 | 2 | – | 2.2(3) | – | – | 2(8) | October 2025 Guidance | 5(2) | Yes – Transposed | – | Yes – Transposed | Note to 1.5.2 | – | Transposed under Section 7 | Transposed under general interpretative provision | 20 December 2024 Decree, Article 3 | 38-10 Ordinance | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Art 1 | 5.8 of the government guidance notes | 2.2 | Transposed by Section HP3 of the ITA | 1-3-1 Regs | 5(9) | – | law, first schedule, 4(8) | Amending law, Art 1,8 | 62 (Enforcement Regulation) | All AG Transposed | Article 1 – regulations | Amendment law 7a | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 5(8) | 3.2.2.1 Communique | 1.9 | 127 | 3(3) decree | |||||||||||||||
| 2.1 | Intra-group transactions accounted at cost | 6_55 Regs | – | Transposed | – | – | – | – | – | – | – | – | – | Yes – Transposed | – | Yes – Transposed | Note to 6.3.1 | – | Transposed under Section 7 | Transposed under general interpretative provision | – | – | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Art 9 | – | – | Transposed by Section HP3 of the ITA | – | – | – | – | – | All AG Transposed | – | Transposed – Article 2 | 5.2.4.1 Communique | Ministerial Decision No. (88) of 2025 | – | ||||||||||||||||||||||
| 2.2 | Excluded Equity Gains or Loss and hedges of investments in foreign operations | 3-35 Regs | 18(3) | Transposed | 15, Regs | 13(5) | – | Normative Reg 12(6) | 18 | – | 6.2 | 17(12) | 2025 law 54b | 15(4) | Ch. 3, 2b (amending law) | 223 VO quaterdecies | 38 | Yes – Transposed | – | Yes – Transposed | Note to 3.2.1 | – | Transposed under Section 7 | 21(11) Regs | 111P(13) | 20 December 2024 Decree, Article 4 | 38-21 Ordinance | Transposed | Art 14, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | 16 | – | 6.2/Article 3 of the Decree | Transposed by Section HP3 of the ITA | 3-2-2 Regs | 61 | 12(19) | 20(14) | 35 (regs) | Amending law, Art 1,13 | 108(2) (Enforcement Decree) | All AG Transposed | Article 4(1) – regulations | December 2024 Amending Law Chapter 4 12 a | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 61 | 5.2.1.3.3 Communique | 3.2.14 | 166 | 4.1.3.4/5, App II, Decree | ||||||||||
| 2.3 | Excluded Dividends- Asymmetric treatment of dividends and distributions | 3_25(2) Regs | – | Transposed | 22, Regs | 9 (commentary) | Normative Reg 9(para 7), 12(2) | 4 | – | 17(bb2) | 39 | – | Ch 1, 30/Ch 3,(5) (amending law) | 223 VO | 17(2) | Yes – Transposed | – | Yes – Transposed | Generally transposed | – | Transposed under Section 7 | 111P | – | Guidance | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | 16 | – | 2.3 | Transposed by Section HP3 of the ITA | 3-2-2 Regs | – | – | Amending law, Art 1,12 | – | All AG Transposed | Article 10 – regulations | December 2024 Amendment Law 9a | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 5.2.1.2 Communique | Ministerial Decision No. (88) of 2025 | 141 | ||||||||||||||||||
| 2.4 | Debt release Election | 3_80 Regs | 24 | Transposed | 19, Regs | 13(6) | March 2025 Budget Law, 260O1 | Normative Art 3(39)/12(11) | 18 | – | 6.2 | 17(13) | 54 | 15(15) | ch. 3, 3a (amending law) | 223 VO duodecies | 39 | Yes – Transposed | – | Yes – Transposed | Note to 3.2.1 | – | Transposed under Section 7 | 22(2) Mentioned but no election | 111P(16) | 20 December 2024 Decree, Article 5 | 38-21 Ordinance | Transposed | Draft Rules, 6 | Art 20, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | 16(12) | – | 6.2 | Transposed by Section HP3 of the ITA | 3-2(Commentary)/3-2-1 Regs | 62 | 20(12) | 29 (regs) | Amending law, Art 1,14 | 123 (Enforcement Decree) | All AG Transposed | Article 4(2) – draft regulations | December 2024 Amending Law Chapter 4 12 b -d | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 62 | 41(b)(4) | 3.2.12 | 151 | 4.2 Decree (appendix II) | ||||||||||
| 2.5 | Accrued Pension Expenses | 3_9/3_75 Regs | 23 | Transposed | 12K, Regs | 9 | – | Normative Art 3(37/38)/12(10) | 18 | – | 17(1)(h) | 2025 law, 40 | 15(11) | Art. 223 VO | 25 | Yes – Transposed | – | Yes – Transposed | Note to 3.2.1 | – | Transposed under Section 7 | Examples | 111P | 23 | Guidance | Transposed | Art 19, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Draft Law, Art 34 | 16 | – | – | Transposed by Section HP3 of the ITA | 3-2 | 51 | 12(2) | 20 | 19 (regs) | Amending law, Art.1.11 | 113 (Enforcement Decree) | All AG Transposed | ch 3, 16 | Transposed – Article 2 | 51 | 5.2.1.9 Communique | 18 | 147 | 4.1.8 Decree (appendix II) | |||||||||||||
| 2.6 | Covered Taxes on deemed distributions | 4_70 Regs | – | Transposed | – | – | 24 | – | 25(5) | – | – | Guidance issued March 2025,7.1 | – | – | Yes – Transposed | – | Yes – Transposed | Note to 4.3.2 | – | Transposed under Section 7 | Transposed under general interpretative provision | – | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | – | – | – | Transposed by Section HP3 of the ITA | – | – | – | – | 129(6) (Enforcement Decree) | All AG Transposed | December 2024 Amending Law Chapter 7. 37 | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | – | 4.3.2 | 181 | |||||||||||||||||||||
| 2.7 | Excess Negative Tax Carry-forward guidance | 4_35 Regs | 41 | Transposed | 52, Regs | 16 | March 2025 Budget Law, 260t(6)/260h(5) | Normative Reg 44/65 | 29/31 | – | Decree to be issued | 22(5b) | 60 | 22 | Guidance issued March 2025, 5.9.2-5.9.4 | 223 VT quater | 44 | Yes – Transposed | – | Yes – Transposed | Note to 4.1.5 | 21(5) refers to AG | Transposed under Section 7 | 111U(9) | 23(6) | Guidance | Transposed | Art 34, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | 21 | – | 7.2(6)/Article 4 of the Executive Decree | Transposed by Section HP3 of the ITA | 4-1(5) | 98/99 | 17(6) | August 2025 Law, Art 25(6)-(10) | 17(4)/21, 24(10) law | 17(3) | 69(4) Law | All AG Transposed | Article 8 – regulations/17(5) – Law | 2024 Amendment Law 37a/b/c and Chapter 4, 19a | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 98/99 | 6.1.4.1/7.2.1.1 Communique | 4.1.6/5.2.6 | 205 | 8.5/8.6 decree (appendix II) | |||||||||||
| 2.8 | Substitute Loss carry forwards | 4_90 Regs | 42(2) | Transposed | Amending law inserts a new Article 17/1 in the GloBE Law. | – | Normative Reg 49(3)/(4) | 25 | – | 23(5) | 63 | 23(9) | Guidance issued March 2025, 5.7.3 | 223 VU octies | 48 | Yes – Transposed | – | Yes – Transposed | Note to 4.4.1 | – | Transposed under Section 7 | Examples | 111X(6) | 20 December 2024 Decree, Article 8 | Guidance | Transposed | Draft Rules, 9 | Art 38, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | 22 | – | 7.3/Article 5 of the Executive Decree | Transposed by Section HP3 of the ITA | 4-1(5) | 90 | 18(8) – transposes the AG provisions | – | 45 (regs) | Amending law, Art 1,22 | 71 (Enforcement Regulation) | All AG Transposed | December 2024 Amendment law, 31a-32d, chapter 3 | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 90 | 6.3.1.1.5 Communique | 4.4.8 | 183 | 9.1.5 Decree (appendix II) | ||||||||||||
| 2.9 | Equity Gain or loss inclusion election | October 2025 Draft Law | 18(4) | Transposed | 21, Regs | 13(7) | March 2025 Budget Law, 260n1 | Normative Reg 12(4) | 18 | – | 6.2(3) – subject to rules | 22(6) | 53 | 15(5) | ch. 3, 23 (amending law) | FA2025, Art 53, (4) | 37 | Yes – Transposed | – | Yes – Transposed | Note to 3.2.4 | Yes referred to in 16(1) | Transposed under Section 7 | 21(13), Regs | 111W | – | Guidance | Transposed | Art 13, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | 16 | – | 6.2/Article 2 of the Executive Decree | Transposed by Section HP3 of the ITA | 3-2-2 Regs | 63 | 12(20) | – | 34 (regs) | Amending law, Art 1,14 | 108(3) (Enforcement Decree) | All AG Transposed | Article 9 – regulations | December 2024 Amendment Law Chapter 4 12 f/g | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 63 | 41(b)(2) | 7.5 | 165 | 4.1.3.4/5, App II, Decree | ||||||||||
| 2.9 | Qualified Ownership Interest/Flow through entity | October 2025 Draft Law | – | 21, Regs | – | March 2025 Budget Law, 260n2 | – | 6.2(3) – subject to rules | 22(6) | 53(3) | 23a | ch. 4, 23 (amending law) | FA2025, Art 53, (9) | 29 | Yes – Transposed | – | Yes – Transposed | Note to 3.2.4 | – | Transposed under Section 7 | 21(13)-(15), Regs | 111W | – | 2024 Tax reform -Basic Provision 18-1-80-3 | Art 59, Regs | March 29, 2024 | 16 | 1.2 | Transposed by Section HP3 of the ITA | 1-5-1(3) Regs | 63 | 12(20) | 42 – Regs | Amending law, Art 1,14 | 108 (Enforcement Decree) | Article 9 – regulations | December 2024 Amendment Law Chapter 4 12 h/i/j/k | Transposed – Article 2 | 5.2.1.3.4 Communique | 3.5.6/7.5 | 176d | 1.3.5, Appendix II, Draft Decree | ||||||||||||||||||||
| 2.1 | Allocation of taxes arising under a Blended CFC Tax Regimes | 4_55/4_60 Regs | 82 | Transposed | Amending law includes a new Article 67/1 | March 2025 Budget Law, 260×1 | 24 | – | Rules to be issued | – | 2025 law, 151a | – | ch 10, 20 (amended law) | – | 85 | Yes – Transposed | – | Yes – Transposed | Note to 4.3.2 | – | Transposed under Section 7 | Examples | 111AA | 20 December 2024 Decree, Article 10 | – | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | 57 | – | 7.5(10)/Article 6 of the Executive Decree | Transposed by Section HP3 of the ITA | 4-1-3 Regs | 151-154 | 20(10) (transposes OECD AG provisions) | – | 44 (regs) | – | 69 (Enforcement Regulation) | All AG Transposed | December 2024 Amendment Law Chapter 7. 63 a – f | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 148 | 6.2.3.1 Communique | Ministerial Decision No. (88) of 2025 | 180 | 3.2-3.4 Appendix II Decree | ||||||||||||||
| 3.1 | Application of Taxable Distribution Method Election to Insurance Investment Entities | 7-140 Regs | 68(1) | Transposed | 61, Regs | – | March 2025 Budget Law, 260y15 | Normative Reg 125 | 42 | – | 44 | 2025 law, 75 | 2(30) | 223WVbis | 7 | Yes – Transposed | – | Yes – Transposed | 7.6.1 | – | Transposed under Section 7 | 111AV | 50(10) | Guidance | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | 43 | – | 10.6 | Transposed by Section HP3 of the ITA | 7-6 | 119 | 39(1) | – | 64, Regs | 30(1) | 159 (Enforcement Decree) | All AG Transposed | Article 45 – Law | 2024 Tax Amendment Law ch 7, 36 | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 119 | 9.4.3 Communique | 18 | 236 | |||||||||||||||
| 3.2 | Exclusion of Insurance Investment Entities from the definition of Intermediate Parent Entity and Partially-Owned Parent Entity | 10_5 Regs | 2(2) | Transposed | – | March 2025 Budget Law, additional provisions (136) | 4 | – | 1.2 | 2 | 2025 law, 6 | 2(30) | October 2025 Guidance | 4 | Yes – Transposed | – | Yes – Transposed | 10.1.1 | – | Transposed under Section 7 | 111A(1) | Annex A – 44/45 | Guidance | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Draft Law, Art 3(16)/(62) | 3 | 157 – only for POPEs | 1.2 | Transposed by Section HP3 of the ITA | 1-5-1 Regs | 2(16) | 3(20)/(22) | 6(38)/(39) | 2 (law) | Amending law, Art 1,6 | 61,law (POPEs) | All AG Transposed | 5(12)/(13) | Amendment law 12/13 | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 2(15)/(16) | – | 18 | 237 | App II, 10.3 Decree | ||||||||||||||
| 3.3 | Restricted Tier 1 Capital | 3-195-3-210 Regs | 33(3) | Transposed | – | – | Normative Reg 20 | 4 | – | 25 | 47 | 15(13) | Ch.3, S12 | 223 VO septies | 29 | Yes – Transposed | – | Yes – Transposed | Generally transposed | – | Transposed under Section 7 | 25, Regs | 111P | 23(17) | 38-19 Ordinance | Transposed | Draft Rules, 4 | Art 29, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Draft Law, Art 39 | Amendment Law, Art 4(2) | 165(24) | – | Transposed by Section HP3 of the ITA | 3-2 Regs | 54 | 12(15) | August 2025 Law, Art 20(11) | 24(3) (regs) | – | 22 | 122 | All AG Transposed | Article 11 – regulations | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 54 | 5.2.11 Communique | 3.2.10 | 35, Law | 155 | 4.8 Decree (appendix II) | |||||||||
| 3.4 | Liabilities related to Excluded Dividends and Excluded Equity Gain or Loss from securities held on behalf of policyholders | 3-40 Regs | 32(3) | Transposed | 26E, Regs | – | – | Normative Reg 12(3) | 18 | – | 17(bc2) | 2025 law, 46 | 15(6) | Ch.3, 2a (amending law) | Art. 223 VO | 31 | Yes – Transposed | – | Yes – Transposed | Note to 3.2.1 | – | Transposed under Section 7 | 111P(15) | – | Guidance | Transposed | Draft Rules, 4 | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment Law, Art 4 | – | – | Transposed by Section HP3 of the ITA | 3-2-2 Regs | 53 | 20(13) | 22(3) (regs) | Amending law, Art 1,17 | – | All AG Transposed | Article 11 – regulations | December 2024 Amending Law Chapter 3, Section 20 | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 53(2) | – | 18 | 153 | ||||||||||||||
| 3.5 | Simplification for Short-term Portfolio Shareholdings | 3_20(2) Regs | 17(2) | Transposed | 20, Regs | Amending Law (amends Article 3(49)) | – | Normative Reg Art 12(1) | 18 | – | 6.2 | 17(3a) | 2025 law, 54a | 15(6) | Ch.3, 2c (amending law) | 223 VO terdecies | 36 | Yes – Transposed | – | Yes – Transposed | Note to 3.2.1 | – | Transposed under Section 7 | 21(10) Regs | 111P(14) | 20 December 2024 Decree, Article 6 | 155-17 Cabinet Order | Transposed | Art 12, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | 16 | – | 6.2(5) | Transposed by Section HP3 of the ITA | 3-2-2 Regs | 56 | 12(18) | 20(13) | 13(3) (regs) | 6(3) | 107 (Enforcement Decree) | All AG Transposed | Article 10(2)(b) | December 2024 Amendment Law Chapter 4 12 e | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 56 | 5.2.1.2.1 Communique | 3.2.13 | 141 | 4.1.2.4 Decree (appendix II) | ||||||||||
| 3.6 | Application of Tax transparency election to Mutual insurance companies | 7_92 Explanatory Notes + Draft Law | 67(2) | Transposed | – | – | 41 | – | – | – | 41 | Ch.7, S13 | – | 71 | Yes – Transposed | – | Yes – Transposed | Note to 7.5.6 | – | Transposed under Section 7 | 49(2), Regs | Transposed under general interpretative provision | 20 December 2024 Decree, Article 7 | 155-17 Cabinet Order | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment Law, Art 10 | – | 10.5 | Transposed by Section HP3 of the ITA | 7-5-1 Regs | – | – | Amending law, Art 1.33 | 158 (Enforcement Decree) | All AG Transposed | Article 2 of the regulations | 2024 Tax Amendment Law ch. 7, s33 | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 118(4) | 9.4.2 Communique | 7.3.3 | 213 | 11.2, App II, Decree | ||||||||||||||||
| 4.1 | Deferred tax assets with respect to tax credits under Article 9.1.1 | 9_10 Regs | 80 | Transposed | 92, Regs | – | – | Normative Reg Art 145 | 46 – Inferred | – | – | – | 51 | Guidance issued March 2025, 5.7.2/11.2 | 223 WX | 79/82 | Yes – Transposed | – | Yes – Transposed | Note to 9.1 | – | Transposed under Section 7 | Examples | Transposed under general interpretative provision | Ministerial Decree of December 27, 2024 | Guidance | Transposed | Art 115, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Article 15(1) | – | – | Transposed by Section HP3 of the ITA | 4-3-1 Regs | 43 | – | 90, Regs | Amending law, Art 1,50 | 161 (Enforcement Decree) | All AG Transposed | First transitional provision – law | 2024 Tax Amendment Law Chapter 4, Sections 25a-c | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 131/132 | 12.3.1 Communique | 9.1.4 | 185 | Appendix II(Section) IV | ||||||||||||
| 4.2 | Applicability of Article 9.1.3 to transactions similar to asset transfers | 9_15 Regs | 80 | Transposed | 92, Regs | – | – | Normative Reg Art 147-150 | 46 | – | – | draft law,141(4) | 51 | Guidance issued March 2025, 5.7.2/11.5.4 | 223 WX | 79 | Yes – Transposed | – | Yes – Transposed | Note to 9.1 | – | Transposed under Section 7 | Examples | Transposed under general interpretative provision | Ministerial Decree of December 27, 2024 | Guidance | Transposed | Art 115, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Article 15(2) | – | 14.1 | Transposed by Section HP3 of the ITA | 4-3-1 Regs | 43 | – | 92, Regs | Amending law, Art 1,50 | 161 (Enforcement Decree) | All AG Transposed | First transitional provision – law | 2024 Tax Amendment Law Chapter 4, Section 28a | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 131/132 | 12.4 Communique | 9.1.7 | Sch 16 | Appendix IV | ||||||||||||
| 4.3 | Asset carrying value and deferred taxes under 9.1.3 | 9_15 Regs | 80 | Transposed | 92, Regs | – | – | Normative Reg Art 147-150 | 46 | – | – | – | 51 | Guidance issued March 2025, 5.7.2/11.5.2 | 223 WX | 79/82b | Yes – Transposed | – | Yes – Transposed | Note to 9.1 | – | Transposed under Section 7 | Examples | Transposed under general interpretative provision | Ministerial Decree of December 27, 2024 | Guidance | Transposed | Art 115, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Article 15(2) | – | 14.1/Article 9 of the Executive Decree | Transposed by Section HP3 of the ITA | 4-3-1 Regs | 43 | – | 92, Regs | Amending law, Art 1,50 | 161 (Enforcement Decree) | All AG Transposed | First transitional provision – law | 2024 Tax Amendment Law Chapter 4, Section 28b | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 131/132 | 12.4 Communique | 9.1.9 | Sch 16 | Appendix IV/App II, Part II, 1.2 | ||||||||||||
| Second Set of OECD Administrative Guidance | – | – | March 29, 2024 | – | – | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||
| 1 | Currency conversion rules | 2_15 | – | Transposed | 72, Regs | – | – | Normative Reg Art 11 | 7 | – | – | 2025 law 36 | – | – | 97 | Yes – Transposed | 12 | Yes – Transposed | Note to 3.2.1 | – | Transposed under Section 7 | 111AAAA | 18(4)/20 December 2024 Decree, Article 9 | – | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Art 11(3) | – | December 2024 Amending law, 3.2(4) | Transposed by Section HP3 of the ITA | 1-4/Regs | 18(9) | 9, law | 45 (Partial) | 163(Enforcement decree) | All AG Transposed | December 2024 Amending Law Ch.1, 4b | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | – | 10 | Schedule 12(33) FA 2024 | |||||||||||||||||||
| 2 | MTTCs | 3-115/3-110-3-145 Regs | 27 | Transposed | 1(19)/23 – Regs | Amending Law (amends Article 3(38)/(39)) | March 2025 Budget Law 260n(9)(a)-(g) | 18(16) | – | – | 17 (as amended by the 2025 law) | 2(38) | ch. 3, 24 (amending law) | FA2025, Art 53,(1) | 27/28/29 | Yes – Transposed | – | Yes – Transposed | Note to 3.2.4 | 21 | Transposed under Section 7 | 111P(5) | 26(6) | 2024 Tax Reform – Basic Provision 18-1-46-4 | Transposed | Art 23, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | 16 | – | December 2024 Amending law, 1.2/6.5/7.2 | Transposed by Section HP3 of the ITA | 3-2(4)/1-5-1 Regs | 65/66 | 12(7) | August 2025 Law, Art 6(21)/20(5)/25(3) | 20 (regs) | Amending law, Art 1,6/9 | 116 (Enforcement decree) | All AG Transposed | Article 6 – regulations | December 2024 Amending law 29a-29f | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 65 | 40/5.2.5 Communique | 3.2.4/18 | Schedule 12(8) of FA 2024 | 1.3.6 Appendix II, Decree | |||||||||||||
| 3 | SBIE Rules | – | – | – | Yes – Transposed | Yes – Transposed | – | – | – | – | – | |||||||||||||||||||||||||||||||||||||||||||||||||||
| – Foreign rules | 5-55/5-65 Regs | 48(5) | Transposed | 47C/D/48 – Regs | – | – | Normative Reg Art 76 | 32 | – | – | 82 | – | Ch.5, 7d (amending law) | FA2025, Art 53, (19)/(20) | 59/60 (for assets. The rules for payroll costs are included in the 2024 Annual Tax Act) | Yes – Transposed | – | Yes – Transposed | Note to 5.3.1 | – | Transposed under Section 7 | 7(6) Regs | 111AE(4) | Art 3, 5 Decree of October 11, 2024 | 2024 Tax Reform – Basic Regulation 18-2-1-2 | Transposed | Draft Rules, 13 | Art 44, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | 28 | – | 8.3(15)/(16) in the December 2024 Amendment law | Transposed by Section HP3 of the ITA | 5-3-3 Regs | 101(4) | 24(3)/(4) | – | 54/55 Regs | Amending law, Art 1,29 | 140(5) (Enforcement decree) | All AG Transposed | Article 5 – regulations | December 2024 Amending law ch 5, 3/4 | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 101 | Notification No. 4 of December 4, 2025 | 7.3.1.2/7.3.2.1 Communique | 5.3.10/5.3.11 | Schedule 12(21) -(25) of FA 2024 | 6.2.1 decree (appendix II) | ||||||||||
| Stock-based compensation election | 5_60 Regs | 48(5) Explanatory Notes | Transposed | – | – | Normative Reg Art 76(4) | 32 -inferred | – | – | – | – | – | – | Yes – Transposed | – | Yes – Transposed | Note to 5.3.1 | – | Transposed under Section 7 | Transposed under general interpretative provision | Art 4, Decree of October 11, 2024 | – | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | – | – | – | Transposed by Section HP3 of the ITA | – | – | – | – | 75 (Enforcement Regulation) | All AG Transposed | Article 5 – regulations | – | Transposed – Article 2 | 7.3.1.3 Communique | Ministerial Decision No. (88) of 2025 | – | |||||||||||||||||||||
| Leases | 5_7 Regs | 48(6) | Transposed | 48, Regs | – | – | Normative Reg Art 77 | 32 | – | – | – | – | ch 5, 7e (amending law) | FA2025, Art 53, (20) | 60 | Yes – Transposed | – | Yes – Transposed | Note to 5.3.1 | – | Transposed under Section 7 | 8(2) + Examples | 111AE(10) | Art 6, Decree of October 11, 2024 | – | Transposed | Draft Rules, 13 | Art 45, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Art 8 | – | 8.3(5) in December 2024 Amendment law/Article 7 of the Executive Decree | Transposed by Section HP3 of the ITA | 5-3-4 Regs | 101(9)/(10) | 24(11) | – | 56 Regs | Amending law, Art 1,29 | 140(4) (Enforcement decree) | All AG Transposed | Article 5 – regulations | December 2024 Amending law ch 5, 4a | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 101 | Notification No. 4 of December 4, 2025 | 7.3.2.1.1 Communique | 5.3.12 | Schedule 12(21) -(25) of FA 2024 | 6.3.1 decree (appendix II) | ||||||||||
| – Impairment losses inc in tangible asset value | 5_65 Regs | 48(7) Explanatory Notes | Transposed | – | – | Normative Reg Art 78 | 32 | – | – | 81 | – | – | 60 | Yes – Transposed | – | Yes – Transposed | Note to 5.3.1 | – | Transposed under Section 7 | Transposed under general interpretative provision | Art 5, Decree of October 11, 2024 | – | Transposed | Draft Rules, 13 | Art 45, Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | 28(4) | – | 8.3(4) – December 2024 Amendment Law | Transposed by Section HP3 of the ITA | 5-3-2 Regs | 101(6) | 24(5) | – | 18(4), draft law | – | 140(3) (Enforcement decree) | All AG Transposed | Article 5 – regulations | – | Transposed – Article 2 | 101 | Notification No. 4 of December 4, 2025 | 7.3.2.3 Communique | 5.3.5 | Schedule 12(21) -(25) of FA 2024 | |||||||||||||||
| 4.1 | QDMTT Safe Harbour | 8_200,-8_220 Regs | 53 | Amending law includes a new Article 62/1 | Chapter 34f | 43 | – | 8.2(9) – High level | Transposed – 33/Ministerial Decree | 144, 2025 law 92a | 34(2) | ch, 9, 10 (amending law) | FA2025, Art 53, (25) | 81 | Yes – Transposed | 36 | Yes – Transposed | Part 3(20) | 32(3)/November Draft Decree, S7 | 28 – draft bill | Transposed under Section 7 | 111AI | 18(7) | 2024 tax reform- 82-2(6) | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | 14 | Yes | 8.13/Article 8 of the Executive Decree | Transposed by Section HP3 of the ITA | 5-7-10 Regs | 125 | 23(8)/(9) | – | 78, Regs | – | 70(5) – details to be prescribed | All AG Transposed | Article 34 – Law | December 2024 Amending law ch 8, s 19/20 | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 125 | 11.4 Communique | Schedule 12(41) of FA 2024 | Art 10 decree | |||||||||||||||
| 4.2 | UTPR Safe Harbour | 8_225 Regs | 57 | Amending law includes a new Article 64/1 | March 2025 Budget Law – Section 260l1 | – | – | Transposed – 33/Ministerial Decree | 148, 2025 law 92m | 75 | ch 10, 19 (amending law) | 223 VZ nonies | 89 | Yes – Transposed | 35 | Yes – Transposed | Part 3(16) | November Draft Decree, S9 | NA | 62, Regs | 111AK | 21(9) /Art 15 of the Decree of May 21, 2024 | – | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | 58 | No | 8.14 | Transposed by Section HP3 of the ITA | Proposed for 2025 in the October 7, 2024 Budget proposals | 149 | 3 | 36(24) | – | – | Art 80, 2024 Amendment Law | All AG Transposed | Sixth transitional provision – law | December 2024 Amending law ch 8, s 14 | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 146 | 11.2 Communique | New Section 12A in Schedule 16 of 2025 Finance Act | |||||||||||||||||
| Third Set of OECD Administrative Guidance | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
| 1 | Transitional CbCR – Purchase Accounting Adjustments (consistent reporting condition, goodwill impairment adjustment) | 8_70(3) Regs | Transposed | March 2025 Budget Law, Art. 260y21 | Normative Reg Art 130(3)-(5) | 47 | Transposed | 2025 law, 92d | 72(4)(4) | ch. 10, 8 (amending law) | FA2025, Art 53, (14) | 2025 Amendment Law 87a | Yes – Transposed | Yes – Transposed | Part 3 (3) | Transposed under Section 7 | Finance Act 2024 – new Art 111AJ(15) | 11, Decree of May 21, 2024 | 2024 Tax Reform Amendment of the Corporate Tax Basic Circular | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Art 18(1) | Yes | 8.8(12) in the December 2024 Amendment states that rules will be provided for PPAs. Rules were issued in the December 2025 Executive Decree amendment (Art 7a) | Transposed by Section HP3 of the ITA | 5-7-31 Regs | 4(11) | 68(5)/(6( Regs | Amending law, Art 1,40 | Amended Section 86 of the 2025 Enforcement Regulations | All AG Transposed | December 2024 Amending law Chapter 8. 6a | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | – | 8.2.1.10 | Finance Act 2025 46(6) | ||||||||||||||||||||||||
| 2.2.1 | Transitional CbCR – JVs | 8_80 Regs | July 2024 Amending Law – 61(1) | Transposed | Normative Reg Art 135 | 47(7) | Transposed | 2025 law, 92j | ch. 10, 9 (amending law) | 2025 Amendment Law 85 | Yes – Transposed | Yes – Transposed | Generally transposed | Transposed under Section 7 | Transposed by S.I. No. 675/2023 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2023 | Various, Decree of May 21, 2024 | Tax Q&A doc | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Art 18(4) | Yes | 8.1 | Transposed by Section HP3 of the ITA | 5-7-33 Regs | 4(3) | 77 Regs | Explanatory Notes | Included in Art 80(3) 2024 Tax Law Amendment . | All AG Transposed | Transposed – Article 2 | 145(3) | – | Ministerial Decision No. (88) of 2025 | ||||||||||||||||||||||||||||
| 2.3.1 | Transitional CbCR – Same Financial Statements/Local Financial Statements for Statutory Reporting | 8_75 Regs | Transposed | Amending Law (amends Article 63) | March 2025 Budget law, Art 260y20(9) | Normative Reg Art 130(10)/(11) | 47 | Transposed | 2025 law, 92d | ch. 10, 7 (amending law) | FA2025, Art 53, (14) | 2025 Amendment Law 87 | Yes – Transposed | Yes – Transposed | Part 3 (4) | Transposed under Section 7 | Transposed by S.I. No. 675/2023 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2023 | 7(5), Decree of May 21, 2024 | Tax Q&A doc | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Art 18(3) | Yes | 8.8(11) in the December 2025 Amending Law | Transposed by Section HP3 of the ITA | 5-7-30 Regs | 4(12) | 74(3), Regs | Explanatory Notes | Amended Section 86 of the 2025 Enforcement Regulations | All AG Transposed | December 2024 Amending law ch 8, section 6 | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | – | 8.2.1.4 | Part V, 6 decree | ||||||||||||||||||||||||
| 2.3.2 | Transitional CbCR – Using different accounting standards | 8_70 Regs, 8_45 explan notes | Transposed | March 2025 Budget law, Art 260y20(10) | Normative Reg Art 130(10) | 47(2) | Transposed | 2025 law, 92d | ch. 10, 7 (amending law) | 2025 Amendment Law 87 | Yes – Transposed | Yes – Transposed | Generally transposed | Transposed under Section 7 | Transposed by S.I. No. 675/2023 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2023 | Tax Q&A doc | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Art 18(3) | Yes | Transposed by Section HP3 of the ITA | 5-7-30 Regs | – | Explanatory Notes | All AG Transposed | December 2024 Amending law ch 8, section 6 | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | |||||||||||||||||||||||||||||||
| 2.3.3 | Transitional CbCR – Adjustments to Qualified Financial Statements/Dividend Mismatches | 8_25 Regs/8.45 Eplanatory Notes | Transposed | March 2025 Budget law, Art 260y20(16) | Normative Reg Art 130(7) | 47(2) | Transposed | 2025 law, 92d/92h | ch. 10, 6 (amending law) | FA2025, Art 53, (14) | 2025 Amendment Law 87 | Yes – Transposed | Yes – Transposed | Generally transposed | Transposed under Section 7 | Transposed by S.I. No. 675/2023 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2023 | 2(6), Decree of May 21, 2024 | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Art 18(3) | Yes | 8.8(6) in the December 2025 Amending Law | Transposed by Section HP3 of the ITA | 5-7-30 Regs | 4(13) | – | Explanatory Notes | All AG Transposed | December 2024 Amending law ch 8, section 7a | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | Finance Act 2025 46(3) | |||||||||||||||||||||||||||
| 2.3.4 | Transitional CbCR – MNEs not required to file CbC Reports | 8_35(4) Regs | July 2024 Amending law – 55(2) | Transposed | 90L, Regs | Amending Law (amends Article 63) | March 2025 Budget law, Art 260y21(6) | Normative Reg Art 127(2) | 47 | Transposed | 2025 law,92l | 72(4) | ch. 10, 5 (amending law) | 223 VZ, FA 2025, Art 53 (14) | 2025 Amendment Law 84 | Yes – Transposed | Yes – Transposed | Part 3 (2)(2) | Autumn 2025 Tax Package, Section 9 | Transposed under Section 7 | Finance Act 2024 – new Art 111AJ(19) | 13, Decree of May 21, 2024 | Tax Q&A doc | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Art 18(3) | Yes | 8.8(10) in the December 2024 Amendment law | Transposed by Section HP3 of the ITA | 5-7-38 Regs | 147(2)(b) | 4(15) | 70(2) Regs | Explanatory Notes | Amended Section 86 of the 2025 Enforcement Regulations | All AG Transposed | December 2024 Amending law ch 8, section 6b/18 | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 144(2) | – | 8.2.1.8 | Schedule 12(29) of FA 2024 | Part V, 3 decree | |||||||||||||||||
| 2.3.5 | Transitional CbCR – Qualified Financial Statements for PEs | 8_70(1) Regs | Transposed | March 2025 Budget Law, Art. 260y20 | Normative Reg Art 130(13) | 47 | Transposed | 2025 law, 92d | ch. 10, 7 (amending law) | 2025 Amendment Law 87 | Yes – Transposed | Yes – Transposed | Part 3 (3) | Transposed under Section 7 | Transposed by S.I. No. 675/2023 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2023 | 12, Decree of May 21, 2024 | Tax Q&A doc | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Art 18(3) | Yes | 8.8(11) in the December 2025 Amending Law | Transposed by Section HP3 of the ITA | 5-7-30 Regs | 147(3) | 4(14) | 68(4) Regs | Explanatory Notes | Amended Section 86 of the 2025 Enforcement Regulations | All AG Transposed | December 2024 Amending law ch 8, section 6 | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 144(3) | – | Ministerial Decision No. (88) of 2025 | |||||||||||||||||||||||||
| 2.4.2 | Transitional CbCR – Treatment of Taxes on income of PEs, CFCs, and Hybrid Entities | 8.25:8.28 Explanatory Notes | Transposed | March 2025 Budget Law, Art. 260y20(8) | Normative Reg Art 130(17) | 47 | Transposed | 2025 law, 92h | 2025 Amendment Law 87 | Yes – Transposed | Yes – Transposed | Generally transposed | Transposed under Section 7 | Finance Act 2024 – new Art 111AJ(16) | 4(5), Decree of May 21, 2024 | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Art 18(3) | Yes | Transposed by Section HP3 of the ITA | – | Explanatory Notes | Amended Section 86 of the 2025 Enforcement Regulations | All AG Transposed | December 2024 Amending law ch 8, section 4a | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | ||||||||||||||||||||||||||||||||
| 2.6 | Transitional CbCR – Treatment of hybrid arbitrage arrangements | 8_110 Regs | July 2024 Amending law – 55(6) | Transposed | 13B Law | Amending Law (amends Article 63) | March 2025 Budget Law, Art. 260y20 (11)-(14) | Normative Reg Art 131 | 47(14) | Transposed | 2025 law, 92d/92i | 72a | ch. 10, 13-18 (amending law) | FA2025, Art 53, (14) | 2025 Amendment Law 87b | Yes – Transposed | Yes – Transposed | Part 3 (13) | Autumn 2025 Tax Package, Section 9 | Transposed under Section 7 | Finance Act 2024 – new Art 111AJ(17)/(18) | 14, Decree of May 21, 2024 | 2024 Tax Reform | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Art 18(5) | Yes | 8.8a in the December 2024 Amendment law | Transposed by Section HP3 of the ITA | 5-7-32 Regs | 148(9)-(20) | 4(17)-(21) | 76, Regs | Amending law, Art 1,45 | Amended Section 86 of the 2025 Enforcement Regulations | All AG Transposed | December 2024 Amending law ch 8, section 11a-g | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 144(9) | – | 8.2.1.3 | Finance Act 2025 47 | Part V, 9 decree | |||||||||||||||||
| 3.1 | Identifying Consolidated Revenue | Transposed | Normative Reg 2(2)/(3) | 2025 law, 8(2) | October 2025 Guidance | Yes – Transposed | Yes – Transposed | Generally transposed | Transposed under Section 7 | Transposed by S.I. No. 675/2023 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2023 | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Art 1 ter | Transposed by Section HP3 of the ITA | Regs, 4 | Included in the 2024 Tax Law Amendment, S62 | All AG Transposed | Transposed – Article 2 | 2.1.1 Communique | Ministerial Decision No. (88) of 2025 | |||||||||||||||||||||||||||||||||||||||||
| 3.2 | Mismatch between Fiscal Years of the UPE and another Constituent Entity | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – art. 2, § 9; art. 3, item XXVII; art. 3, § 31B; art. 63, § 3; art. 73, § 3; art. 147 | ch 1, 10 (amended law) | Yes – Transposed | Yes – Transposed | Generally transposed | Transposed under Section 7 | Transposed by S.I. No. 675/2023 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2023 | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Art 2(1) | 6.1 December 2025 Amending Law | Transposed by Section HP3 of the ITA | Law, First schedule, 6 | All AG Transposed | Article 3 – regulations | Transposed – Article 2 | 156 | 2.1.1 Communique | Ministerial Decision No. (88) of 2025 | ||||||||||||||||||||||||||||||||||||||||
| 3.3 | Mismatch between Fiscal Year and Tax Year of Constituent Entity | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – art. 2, § 9; art. 3, item XXVII; art. 3, § 31B; art. 63, § 3; art. 73, § 3; art. 147 | 2025 law 37a | Yes – Transposed | Yes – Transposed | Generally transposed | Transposed under Section 7 | Transposed by S.I. No. 675/2023 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2023 | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment, Art 2(1) | 6.1 December 2025 Amending Law | Transposed by Section HP3 of the ITA | – | All AG Transposed | Article 3 – regulations | Transposed – Article 2 | 156 | 6.1 Communique | Ministerial Decision No. (88) of 2025 | ||||||||||||||||||||||||||||||||||||||||
| 4.2.1 | Blended CFCs -multiple GloBE Jurisdictional ETRs | 2025 Tax Amendment Act, Article 3 (25) | Transposed | Amending law includes a new Article 67/1 | March 2025 Budget Law, 260×1 | 24(4) | 2025 law, 151a | ch 10, 21/22 (amended law) | 2025 Amendment Law 88 | Yes – Transposed | Yes – Transposed | Note to 4.3.2 | Transposed under Section 7 | Transposed by S.I. No. 675/2023 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2023 | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Article 17 | 7.5(10) – further rules to be issued | Transposed by Section HP3 of the ITA | 20(10) (transposes OECD AG provisions) | All AG Transposed | December 2024 Amending Law Chapter 7. 63 a – f | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 148-150 | – | Ministerial Decision No. (88) of 2025 but not relevant for a QDMTT as no pushdown | Section 25 of finance Act, 2025 | |||||||||||||||||||||||||||||||||
| 4.2.2 | Blended CFCs – not required to calculate an ETR | 2026 Tax Amendment Act, Article 3 (25) | Transposed | Amending law includes a new Article 67/1 | March 2025 Budget Law, 260×1 | 24(4) | 2025 law, 151a | ch 10, 21/22 (amended law) | 2025 Amendment Law 88 | Yes – Transposed | Yes – Transposed | Note to 4.3.2 | Transposed under Section 7 | Transposed by S.I. No. 675/2023 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2023 | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Article 17 | 7.5(10) – further rules to be issued | Transposed by Section HP3 of the ITA | 20(10) (transposes OECD AG provisions) | All AG Transposed | December 2024 Amending Law Chapter 7. 63 a – f | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 148-150 | – | Ministerial Decision No. (88) of 2025 but not relevant for a QDMTT as no pushdown | Section 25 of finance Act, 2025 | |||||||||||||||||||||||||||||||||
| 4.2.3 | Blended CFCs – income of non-GloBE Entities | 2027 Tax Amendment Act, Article 3 (25) | Transposed | Amending law includes a new Article 67/1 | March 2025 Budget Law, 260×1 | 24(4) | 2025 law, 151a | ch 10, 21/22 (amended law) | 2025 Amendment Law 88 | Yes – Transposed | Yes – Transposed | Note to 4.3.2 | Transposed under Section 7 | Transposed by S.I. No. 675/2023 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2023 | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Article 17 | 7.5(10) – further rules to be issued | Transposed by Section HP3 of the ITA | 20(10) (transposes OECD AG provisions) | All AG Transposed | December 2024 Amending Law Chapter 7. 63 a – f | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 148-150 | – | Ministerial Decision No. (88) of 2025 but not relevant for a QDMTT as no pushdown | Section 25 of finance Act, 2025 | |||||||||||||||||||||||||||||||||
| 5.3 | 30 June 2026 Filing deadline | 69 of the Consequential Act | 72(3) | Transposed | March 2025 Budget Law, 30(1) | 55 | 57 | 2025 law, 151b | 53(4) | 2025 Amendment Law 75 | Yes – Transposed | Yes – Transposed | Generally transposed | Transposed under Section 7 | Finance Act 2024 – new Art 111AAF(5) | 2024 Tax reform art 22 amend | Transposed | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Amendment law, Article 16 | Transposed by Section HP3 of the ITA | 156 | – | Amending law, Art 1,53 | Art 80, 2024 Tax Law Amendment . | All AG Transposed | regulations – 3rd transitional provision | Transitional provision to the Act (2023:880) amending the Tax Procedure Act. | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 153(1) | – | Ministerial Decision No. (88) of 2025 | Section 52 of finance Act, 2025 | ||||||||||||||||||||||||||||
| 6 | NMCE Simplified Calcs | 8_175-8_185 Regs | 54/ 2025 Tax Amendment Act, Article 3 (10) | Transposed | 14 | Amending law inserts a new Article 62/2 in the GloBE Law. | 260(3) | Normative Reg 142 | 45/46 | Transposed | 2025 law, 92c (Permament simplified safe harbour, 92b) | 34a | ch 9, 11 (amending law) | FA2025, Art 53, (2) | Yes – Transposed | Yes – Transposed | Part 3, division 5 | November Draft Decree, S8 | Transposed under Section 7 | 63, Regs | Finance Act 2024 – new Art 111AKA | 2024 tax reform- 82-2(8) | Transposed | Art 60 Regs | Transposed Art. 2 of the GloBE Regulation | March 29, 2024 | Art 32 | Yes – section 10 December 2024 MIRB Guidance | 8.11 – further rules to be issued | Transposed by Section HP3 of the ITA | 5-7-21 Regs | 126/127 | 42 | 84-86 Regs | Amending law, Art 1,45 | All AG Transposed | December 2024 Amending law ch 8, s 15-17 | January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023 | Transposed – Article 2 | 127 | 11.3 Communique | 8.2.2 | July 2025 Draft Law – Para 22 | Art 12 decree | ||||||||||||||||||
| Fourth Set of OECD Administrative Guidance | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
| 1.2.1 | Aggregate DTL Category basis | 2025 Tax Amendment Act, Article 3 (7) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 52A-52J | Applies via interpretation/Section 1(8) August 2025 Draft Law | Guidance issued March 2025, 5.8.2/November 2025 Draft Law, Ch4 | Finance Bill 2026, Art 26 | 2025 Amendment Law 50a | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | Finance Act 2024 – new Art 111X(11) | Article 38-32 of the 2025 amended Enforcement Regulations | Transposed | Amendment law art 6(2) – subject to regulation | 7.3 December 2025 Amending Law – rules to be issued, December 2025 Executive Decree provides the detailed rules(6.6a) | 2025 Draft Bill/Regs | October 2025 Amendment Law – Section 18, paragraph 1, letter b), Section 18, paragraphs 10 to 15 and Section 18b | 2025 Amendment to Art 113 of the Enforcement Decree – February 28, 2025 | Applicable under general interpretative provisions | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | Section 30, Finance Act 2025 | |||||||||||||||||||||||||||||||||||||
| 1.2.1 | Exclusion of certain types of GL accounts and separate tracking | 2025 Tax Amendment Act, Article 3 (7) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 52A-52J | Applies via interpretation/Section 1(8) August 2025 Draft Law | Guidance issued March 2025, 5.8.2/November 2025 Draft Law, Ch4 | Finance Bill 2026, Art 26 | 2026 Amendment Law 50a | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | Finance Act 2024 – new Art 111X-(12) | Article 38-32 of the 2025 amended Enforcement Regulations | Transposed | Amendment law art 6(2) – subject to regulation | 7.3 December 2025 Amending Law – rules to be issued, December 2025 Executive Decree provides the detailed rules(6.6a) | 2025 Draft Bill/Regs | October 2025 Amendment Law – Section 18, paragraph 1, letter b), Section 18, paragraphs 10 to 15 and Section 18b | Amended Section 74(2) of the 2025 Enforcement Regulations | Applicable under general interpretative provisions | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | Section 30, Finance Act 2025 | |||||||||||||||||||||||||||||||||||||
| 1.2.1 | Exclusion of GL accounts that generate standalone DTAs | 2025 Tax Amendment Act, Article 3 (7) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 52A-52J | Applies via interpretation/Section 1(8) August 2025 Draft Law | Guidance issued March 2025, 5.8.2/November 2025 Draft Law, Ch4 | Finance Bill 2026, Art 26 | 2027 Amendment Law 50a | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | Finance Act 2024 – new Art 111X(13) | Article 38-32 of the 2025 amended Enforcement Regulations | Transposed | Amendment law art 6(2) – subject to regulation | 7.3 December 2025 Amending Law – rules to be issued, December 2025 Executive Decree provides the detailed rules(6.6a) | 2025 Draft Bill/Regs | October 2025 Amendment Law – Section 18, paragraph 1, letter b), Section 18, paragraphs 10 to 15 and Section 18b | Amended Section 74(2) of the 2025 Enforcement Regulations | Applicable under general interpretative provisions | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | Section 30, Finance Act 2025 | |||||||||||||||||||||||||||||||||||||
| 1.2.1 | Exclusion of swinging accounts and separate tracking | 2025 Tax Amendment Act, Article 3 (7) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 52A-52J | Applies via interpretation/Section 1(8) August 2025 Draft Law | Guidance issued March 2025, 5.8.2/November 2025 Draft Law, Ch4 | Finance Bill 2026, Art 26 | 2028 Amendment Law 50a | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | Finance Act 2024 – new Art 111X(13) | Article 38-32 of the 2025 amended Enforcement Regulations | Transposed | Amendment law art 6(2) – subject to regulation | 7.3 December 2025 Amending Law – rules to be issued, December 2025 Executive Decree provides the detailed rules(6.6a) | 2025 Draft Bill/Regs | October 2025 Amendment Law – Section 18, paragraph 1, letter b), Section 18, paragraphs 10 to 15 and Section 18b | Amended Section 74(2) of the 2025 Enforcement Regulations | Applicable under general interpretative provisions | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | Section 30, Finance Act 2025 | |||||||||||||||||||||||||||||||||||||
| 1.2.2 | FIFO/LIFO Basis | 2025 Tax Amendment Act, Article 3 (7) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 52A-52J | Applies via interpretation/Section 1(8) August 2025 Draft Law | Guidance issued March 2025, 5.8.3/November 2025 Draft Law, Ch4 | Finance Bill 2026, Art 26 | 2029 Amendment Law 50a | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | Finance Act 2024 – new Art 111X(14)/15) | Article 38-32 of the 2025 amended Enforcement Regulations | Transposed | Amendment law art 6(2) – subject to regulation | 7.3 December 2025 Amending Law – rules to be issued, December 2025 Executive Decree provides the detailed rules(6.6a) | 2025 Draft Bill/Regs | October 2025 Amendment Law – Section 18, paragraph 1, letter b), Section 18, paragraphs 10 to 15 and Section 18b | Amended Section 74(2) of the 2025 Enforcement Regulations | Applicable under general interpretative provisions | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | Section 30, Finance Act 2025 | |||||||||||||||||||||||||||||||||||||
| 1.2.3 | Aggregation of Short-term DTLs | 2025 Tax Amendment Act, Article 3 (7) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 52A-52J | Applies via interpretation/Section 1(8) August 2025 Draft Law | Guidance issued March 2025, 5.8.3/November 2025 Draft Law, Ch4 | Finance Bill 2026, Art 26 | 2030 Amendment Law 50a | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | S.I. No. 551/2024 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2024 | Article 38-32 of the 2025 amended Enforcement Regulations | Transposed | Amendment law art 6(2) – subject to regulation | 7.3 December 2025 Amending Law – rules to be issued, December 2025 Executive Decree provides the detailed rules(6.6a) | 2025 Draft Bill/Regs | October 2025 Amendment Law – Section 18, paragraph 1, letter b), Section 18, paragraphs 10 to 15 and Section 18b | Amended Section 74(2) of the 2025 Enforcement Regulations | Applicable under general interpretative provisions | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | Section 30, Finance Act 2025 | |||||||||||||||||||||||||||||||||||||
| 1.2.2 | Reversal of DTLs that accrued before the Transition Year | 2025 Tax Amendment Act, Article 3 (7) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 52A-52J | Applies via interpretation/Section 1(8) August 2025 Draft Law | 23(8) June 2025 amendment law | Guidance issued March 2025, 5.8.3/November 2025 Draft Law, Ch4 | Finance Bill 2026, Art 26 | 2031 Amendment Law 50a | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | S.I. No. 551/2024 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2024 | Article 38-32 of the 2025 amended Enforcement Regulations | Transposed | Amendment law art 6(2) – subject to regulation | 7.3 December 2025 Amending Law – rules to be issued, December 2025 Executive Decree provides the detailed rules(6.6a) | 2025 Draft Bill/Regs | October 2025 Amendment Law – Section 18, paragraph 1, letter b), Section 18, paragraphs 10 to 15 and Section 18b | Amended Section 71 of the 2025 Enforcement Regulations | Applicable under general interpretative provisions | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | Section 30, Finance Act 2025 | ||||||||||||||||||||||||||||||||||||
| 1.2.2 | 5 year unclaimed accrual election | 2025 Tax Amendment Act, Article 3 (6) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 53A | Section 1(8) August 2025 Draft Law | 23(8) June 2025 amendment law | Guidance issued March 2025, 5.8.1/November 2025 Draft Law, Ch4 | 2025 Amendment Law 50 | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | S.I. No. 551/2024 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2024 | Article 38-32 of the 2025 amended Enforcement Regulations | Transposed | Amendment law art 6(2) – subject to regulation | 7.3 December 2025 Amending Law – rules to be issued, December 2025 Executive Decree provides the detailed rules(6.6a) | 2025 Draft Bill/Regs | October 2025 Amendment Law – Section 18, paragraph 1, letter b), Section 18, paragraphs 10 to 15 and Section 18b | Amended Section 71 of the 2025 Enforcement Regulations | Applicable under general interpretative provisions | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | Section 30, Finance Act 2025 | |||||||||||||||||||||||||||||||||||||
| 2.1.2 | Recalculated deferred tax where GloBE carrying value differs from accounting carrying value | 2025 Tax Amendment Act, Article 3 (6) | Transposed | 34, Regs | Normative Instruction RFB No. 2282, of October 2, 2025 – 50A | Applies via interpretation/Section 1(8) August 2025 Draft Law | 23(6) June 2025 amendment law | November 2025 Draft Law, Ch3, 13a | 2025 Amendment Law 50 | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | Finance Act 2024 – new Art 111X(16) | Transposed | Amendment law art 6(2) – subject to regulation | 6.6a/7.3 December 2025 Amending Law | 2025 Draft Bill/Regs | October 2025 Amendment Law – Section 18, paragraph 16 | Amended Section 70 of the 2025 Enforcement Regulations | Ch.3, 30a – December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | Section 12 of Finance Act, 2025 | ||||||||||||||||||||||||||||||||||||
| 2.1.2 | GloBE and accounting carrying values and the Transition Rules | 2025 Tax Amendment Act, Article 3 (6) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 78 | Applies via interpretation/Section 1(8) August 2025 Draft Law | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | S.I. No. 551/2024 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2024 | Transposed | Amendment law art 6(2) – subject to regulation | 2025 Draft Bill/Regs | Included in commentary | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | |||||||||||||||||||||||||||||||||||||||||||||
| 2.1.2 | Additional provisions for Intragroup transactions accounted for at cost | Transposed | Applies via interpretation/Section 1(8) August 2025 Draft Law | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | S.I. No. 551/2024 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2024 | Transposed | Amendment law art 6(2) – subject to regulation | 2025 Draft Bill/Regs | Included in commentary | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | |||||||||||||||||||||||||||||||||||||||||||||||
| 2.1.2 | Exclusion of GloBE carrying value from SBIE | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 78 | Applies via interpretation/Section 1(8) August 2025 Draft Law | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | S.I. No. 551/2024 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2024 | Transposed | Amendment law art 6(2) – subject to regulation | Not necessary | Amended Section 75 of the 2025 Enforcement Regulations | Included in commentary | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | |||||||||||||||||||||||||||||||||||||||||||||
| 3.1.3 | General rules for allocating cross-border, current taxes under a cross-crediting corporate tax system: 4 Steps | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 48A-48F | Applies via interpretation | November 2025 Draft Law, Ch4, 19a/November 25 Guidance – Section 2.4.3 | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | S.I. No. 551/2024 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2024 | Transposed | Amendment law art 6(2) – subject to regulation | 7.5 December 2025 Amending Law – Rules to be issued, December 2025 Executive Decree provides the detailed rules(6.6b) | 2025 Draft Regs | October 2025 Amendment Law- 19(10) – subject to MoF Regulation | Ch.3, 27a -27o – December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | 6.2.1 Communique | Ministerial Decision No. (88) of 2025 implements the AG. However, no taxes are pushed down under the QDMTT rules | Section 27 of Finance Act, 2025 | |||||||||||||||||||||||||||||||||||||||||
| 3.1.3 | Specific rules for foreign PEs/CFCs, Hybrids/rev hybrids with domestic source income | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 48A-48F | Applies via interpretation | 23(9) – June 2025 amendment law | November 2025 Draft Law, Ch4, 19a/November 25 Guidance – Section 2.4.3 | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | S.I. No. 551/2024 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2024 | Transposed | Amendment law art 6(2) – subject to regulation | 7.5 December 2025 Amending Law – Rules to be issued, December 2025 Executive Decree provides the detailed rules(6.6b) | 2025 Draft Regs | October 2025 Amendment Law- 19(10) – subject to MoF Regulation | Ch.3, 27 d–27 i – December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | 6.2.1 Communique | Ministerial Decision No. (88) of 2025 implements the AG. However, no taxes are pushed down under the QDMTT rules | Section 27 of Finance Act, 2025 | ||||||||||||||||||||||||||||||||||||||||
| 3.1.3 | Cross-crediting between Permanent Establishments and distributions from foreign subsidiaries | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 48A-48F | Applies via interpretation | 23(9) – June 2025 amendment law | November 2025 Draft Law, Ch4, 19a/November 25 Guidance – Section 2.4.3 | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | S.I. No. 551/2024 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2024 | Transposed | Amendment law art 6(2) – subject to regulation | 7.5 December 2025 Amending Law – Rules to be issued, December 2025 Executive Decree provides the detailed rules(6.6b) | 2025 Draft Regs | October 2025 Amendment Law- 19(10) – subject to MoF Regulation | Ch.3, 27 d–27 i – December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | 6.2.1 Communique | Ministerial Decision No. (88) of 2025 implements the AG. However, no taxes are pushed down under the QDMTT rules | Section 27 of Finance Act, 2025 | ||||||||||||||||||||||||||||||||||||||||
| 4.1 | Extension of the Substitute Loss Carry-forward DTA to PEs, hybrids and rev hybrids | 2025 Tax Amendment Act, Article 3 (6) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 49 | Section 1(4)/(5) August 2025 Draft Law | 23(9) – June 2025 amendment law | Guidance issued March 2025, 5.7.3/November 25 Guidance – Section 2.6.6 | 2025 Amendment Law 50 | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | S.I. No. 551/2024 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2024 | Transposed | Amendment law art 6(2) – subject to regulation | 7.5 December 2025 Amending Law – Rules to be issued | Not necessary | Amended Section 71 of the 2025 Enforcement Regulations | Ch.3, 34c – December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | Section 29 of Finance Act, 2025 | ||||||||||||||||||||||||||||||||||||||
| 4.2 | Allocation of deferred tax expenses and benefits from a Parent Entity to a CFC, PE Hybrid or Rev Hybrid: 5 step process | 2025 Tax Amendment Act, Article 3 (6) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 47(7)/49 | Section 1(7) August 2025 Draft Law | November 2025 Draft Law, Ch4, 19b/November 25 Guidance – Section 2.5.2 | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | S.I. No. 551/2024 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2024 | Regulations for Enforcement of the Corporation Tax Law, Article 38-55 | Transposed | Amendment law art 6(2) – subject to regulation | 7.5 December 2025 Amending Law – Rules to be issued, December 2025 Executive Decree provides the detailed rules(6.6c) | 2025 Draft Bill/Regs | October 2025 Amendment Law- 19(10) – subject to MoF Regulation | Amended Section 70 of the 2025 Enforcement Regulations | Ch.3, 27m-27o – December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 implements the AG. However, no taxes are pushed down under the QDMTT rules | Section 28 of Finance Act, 2025 | ||||||||||||||||||||||||||||||||||||||
| 4.2.2 | Five-Year Election to exclude the allocation of all deferred tax expenses and benefits to CFCs, PEs, Hybrids and Rev Hybrids | 2026 Tax Amendment Act, Article 3 (8) | Transposed | Included in the QDMTT Return | Section 1(7) August 2025 Draft Law | November 2025 Draft Law, Ch4, 19b/November 25 Guidance – Section 2.5.3 | 2025 Amendment Law 49 | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | Finance Act 2024 – new Art 111Z(9a) | Regulations for Enforcement of the Corporation Tax Law, Article 38-56 | Transposed | Amendment law art 6(2) – subject to regulation | 7.5 December 2025 Amending Law – Rules to be issued, December 2025 Executive Decree provides the detailed rules(6.6c) | 2025 Draft Bill/Regs | October 2025 Amendment Law- 19(11) | Amended Section 71 of the 2025 Enforcement Regulations | Ch.4, 16a – December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | – | No – not relevant for a QDMTT as no taxes pushed down | Section 28 of Finance Act, 2025 | |||||||||||||||||||||||||||||||||||||
| 4.2.3 | Exclusion of deferred tax assets or liabilities arising under a Blended CFC regime from transition rules | 2025 Tax Amendment Act, Article 3 (6) | Transposed | Section 1(12) August 2025 Draft Law | 2025 Amendment Law 50 | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | S.I. No. 551/2024 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2024 | Ministerial Decree of December 27, 2024 | Transposed | Amendment law art 6(2) – subject to regulation | 7.5 December 2025 Amending Law – Rules to be issued, December 2025 Executive Decree provides the detailed rules(6.6c) | 2025 Draft Bill/Regs | Ch.3, 27 d–27 i – December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | 12.3.1 Communique | No – not relevant for a QDMTT as no taxes pushed down | Section 31 of Finance Act, 2025 | |||||||||||||||||||||||||||||||||||||||||
| 5.2.2 | Determining GloBE status when a Flow-through Entity is held directly by another Flow-through Entity | 2025 Tax Amendment Act, Article 3 (4) | Transposed | 11e, Regs | Normative Instruction RFB No. 2282, of October 2, 2025 – 29A-29E | 3(1) draft law) | 4(12) – June 2025 amendment law | November 25 Guidance – Section 5.2 | 2025 Amendment Law 7(32) | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | Examples | Finance Act 2024 – new Art 111A(5A) | Transposed | Amendment law, Art 2(2) | 1.2(1) December 2025 Amending Law | 2025 Draft Regs | Finance (Income Taxes) Bill 2025, S6E/6F | October 2025 Amendment Law- § 2 letter and ab ), § 2 letter and ac ), § 2 letter bs ) and § 14 par. 4 | Amended Section 108 of the 2025 Enforcement Decree | Ch 7, 3 – December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | 5.4.2 Communique | Ministerial Decision No. (88) of 2025 | 13, Finance Act 2025 | ||||||||||||||||||||||||||||||||||
| 5.3.2 | Non-group owners: Partially owned Flow-through Entities | 2025 Tax Amendment Act, Article 3 (4)/(5) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 29A-29E | 4(1) draft law) | 18(1) – June 2025 amendment law | November 25 Guidance – Section 4.3.4 | 2025 Amendment Law 7(32) | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | Examples | S.I. No. 551/2024 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2024 | Transposed | Amendment law, Art 5(1) | 6.14 December 2025 Amending Law | 2025 Draft Regs | Finance (Income Taxes) Bill 2025, 1(5) of the First Schedule | October 2025 Amendment Law- § 14 par. 1 letter b) | Amended Section 108 of the 2025 Enforcement Decree | Ch 7, 6 – December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | 5.4.3 Communique | Ministerial Decision No. (88) of 2025 | 13, Finance Act 2025 | |||||||||||||||||||||||||||||||||||
| 5.3.5 | Non-group owners: Indirect minority ownership | 2025 Tax Amendment Act, Article 3 (4) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 29A-29E | 4(1) draft law) | 4(12) – June 2025 amendment law | November 25 Guidance – Section 4.3.4 | 2025 Amendment Law 7(32) | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | Examples | S.I. No. 551/2024 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2024 | Transposed | Amendment law, Art 5(1) | 6.14 December 2025 Amending Law | 2025 Draft Regs | Finance (Income Taxes) Bill 2025, 1(1)(aa) of the First Schedule | October 2025 Amendment Law – § 14 par. 1 letter b) | Amended Section 108 of the 2025 Enforcement Decree | Ch 7, 6 – December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | 5.4.3 Communique | Ministerial Decision No. (88) of 2025 | 13, Finance Act 2025 | |||||||||||||||||||||||||||||||||||
| 5.4.2 | Taxes allocated to a flow-through entity | 2025 Tax Amendment Act, Article 3 (8) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 29A-29E | 5(1) draft law)/Section 1(7) August 2025 Draft Law | 25(2) – June 2025 amendment law | November 25 Guidance – Section 4.4 | 2025 Amendment Law 49 | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | Examples | S.I. No. 551/2024 – Taxes Consolidation Act 1997 (Section 111B(3)) Order 2024 | Transposed | Amendment law, art 7(1) | 7.5 December 2025 Amending Law | 2025 Draft Regs | Finance (Income Taxes) Bill 2025, 1(3)(d) of the First Schedule | October 2025 Amendment Law – § 2 letter and ab ), § 2 letter and ac ), § 2 letter bs ) and § 14 par. 4 | Amended Section 108 of the 2025 Enforcement Decree | Ch 3, 27a/Ch 7, 3/4/8- December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | 6.2.2 Communique | Ministerial Decision No. (88) of 2025 | 16, Finance Act 2025 | |||||||||||||||||||||||||||||||||||
| 5.5.2 | Hybrid entities – Taxes pushed down include indirect owners | 2025 Tax Amendment Act, Article 3 (8) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 29A-29E | Applies via interpretation | November 2025 Draft Law, Ch2, 17/November 25 Guidance – Section 4.2.6 | 2025 Amendment Law7(32) | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | Finance Act – 111A definition | Transposed | Amendment law, art 7(2) | 1.2(1) December 2025 Amending Law | 2025 Draft Regs | Finance (Income Taxes) Bill 2025, S3(2)/3(3) | October 2025 Amendment Law – § 2 letter and ab ), § 2 letter and ac ), § 2 letter bs ) and § 14 par. 5 | Amended Section 108 of the 2025 Enforcement Decree | Ch 7, 3/4/8- December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | 6.2.4 Communique | Ministerial Decision No. (88) of 2025 implements the AG. However, no taxes are pushed down under the QDMTT rules | 13-16, Finance Act 2025 | |||||||||||||||||||||||||||||||||||||
| 5.5.4 | Hybrid entities – Entities located in jurisdictions without a Corporate Income Tax system | 2025 Tax Amendment Act, Article 3 (4) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 31A | Applies via interpretation | November 25 Guidance – Section 4.2.6/4.6 | 2025 Amendment Law 7(32) | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | Finance Act – 111A definition | Transposed | Amendment law, art 7(2) | 1.2(1) December 2025 Amending Law | 2025 Draft Regs | October 2025 Amendment Law- § 2 letter and ab ), § 2 letter and ac ), § 2 letter bs ) and § 14 par. 6 | Amended Section 108 of the 2025 Enforcement Decree | Included in commentary | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 implements the AG. However, no taxes are pushed down under the QDMTT rules | 13-16, Finance Act 2025 | ||||||||||||||||||||||||||||||||||||||
| 5.6.2 | Extension of taxes pushed down to include Reverse Hybrids | 4_65 Regs | 2025 Tax Amendment Act, Article 3 (8) | Transposed | Normative Instruction RFB No. 2282, of October 2, 2025 – 47 | Section 1(7) August 2025 Draft Law | 25(4) -June 2025 amendment law | November 2025 Draft Law, Ch2, 17/Ch4, 18 | 2025 Amendment Law 49 | Yes – Transposed | Yes – Transposed | Transposed under Schedule 64 | Transposed under Section 7 | Section 115(g) of the 2024 Finance Act applies this to a hybrid or a reverse hybrid entity. | Transposed | Amendment law, art 7(2) | 7.5 December 2025 Amending Law | 2025 Draft Bill | October 2025 Amendment Law – § 17 paragraph 7 and § 19 paragraph 4 | 2025 Amendment to Art 111 of the Enforcement Decree | Article 20(4) – Law | Ch 3, 27(5) – December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | 6.2.4 Communique | Ministerial Decision No. (88) of 2025 implements the AG. However, no taxes are pushed down under the QDMTT rules | 16, Finance Act 2025 | |||||||||||||||||||||||||||||||||||
| 6.1.4 | Option to exclude a Securitization Entity from scope of QDMTT | 52 (draft law) | Yes – Transposed | Yes – Transposed | No | No | Part of consultation | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | 267 | |||||||||||||||||||||||||||||||||||||||||||||||||||
| 6.1.4 | Option to not impose top-up tax liabilities on SPVs used in securitization transactions | 2_35 Regs | Normative Instruction RFB No. 2282, of October 2, 2025 – 89A | 49.3/51 (draft law) | November 2025 Draft Law, Ch2, 15 | Yes – Transposed | Yes – Transposed | No | Finance Act 2024 – new Art 111A(8)(d)/Art AAC(4) | Amendment Law, Art 12 | 2025 Draft Bill – UTPR exclusion | Article 25(4) of the Law | Ch.6, 2a-2c – December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | |||||||||||||||||||||||||||||||||||||||||||||
| 6.1.4 | Amendments to the Switch-Off rule | 8_210 Regs | 2025 Tax Amendment Act, Article 3 (10) | Transposed | March 2025 Budget Law 260y2(2) | Section 1(10) August 2025 Draft Law | Transposed | 4(48)/34(3) June 2025 amendment law | 2025 Amendment Law 81 | Yes – Transposed | Yes – Transposed | Schedule 61, division 4, 24A (April 2025 amendment) | Transposed under Section 7 | Finance Act 2024 – new Art 111AI(4)(d) | Transposed | December 2025 Executive Decree Amendments (Art 8) | 2025 Draft Bill/Regs | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | ||||||||||||||||||||||||||||||||||||||||||
| 6.1.4 | New definition: Securitization Entity | 8_215 Regs | 2025 Tax Amendment Act, Article 3 (4) | Transposed | March 2025 Budget Law 260y2(3) | Normative Instruction RFB No. 2282, of October 2, 2025 – 89B | 2(1) draft law | 4(52) June 2025 amendment law | November 2025 Draft Law, Ch2, 15 | 2025 Amendment Law 7(33a) | Yes – Transposed | Yes – Transposed | Schedule 61, 25 | No | Finance Act 2024 – new Art 111A(II) | Transposed | Amendment law, art 2(4) | December 2025 Executive Decree Amendments (Art 8) | 2025 Draft Regs | Finance (Income Taxes) Bill 2025, S6G | Article 25(4) of the Law | Ch.6, 2c – December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | 267 | |||||||||||||||||||||||||||||||||||
| 6.1.4 | New definition: Securitization Arrangement | 8_220 Regs | 2025 Tax Amendment Act, Article 3 (4) | Transposed | March 2025 Budget Law 260y2(3) | Normative Instruction RFB No. 2282, of October 2, 2025 – 89B | 2(1) draft law | 4(51) June 2025 amendment law | November 2025 Draft Law, Ch2, 15 | 2025 Amendment Law 7(33b) | Yes – Transposed | Yes – Transposed | Schedule 61, 25 | No | Finance Act 2024 – new Art 111A(II) | Transposed | Amendment law, art 2(4) | December 2025 Executive Decree Amendments (Art 8) | 2025 Draft Regs | Finance (Income Taxes) Bill 2025, S6H | Article 25(4) of the Law | Ch.6, 2c – December 2025 amendment law | Tax years beginning immediately after December 31, 2025, however, the reporting entity may apply all or some of the provisions for tax years beginning immediately after December 31, 2023. | Transposed – Article 2 | – | Ministerial Decision No. (88) of 2025 | ||||||||||||||||||||||||||||||||||||
| January 2025 OECD Administrtive Guidance | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
| 1 | Articles 8.1.4 and 8.1.5 | Transposed under Schedule 64 | Transposed under the 2025 amended law. Applies in respect of any Fiscal Year beginning on or after June 17, 2025. | Ministerial Decision No. (88) of 2025 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
| 1 | Amendments to CbCR Safe Harbour for 9.1 | 2025 Tax Amendment Act, Article 3 (12) | Section 1(12) August 2025 Draft Law | 2025 Law, 92g | 72(4) | November 2025 Draft Law, Ch10, 6 | 2025 Amendment Law 87 | Schedule 61, Part 3(1) | Transposed under the 2025 amended law | Finance Bill 2025, Section 92 | Art 9 – December 2025 Amendment Law | 8.8 December 2025 Amending Law | 2025 Draft Bill/Regs | October 2025 Amendment Law – § 32 par. 10 to 12 and § 46b | Transposed – Article 2 | 12.3.2.1 Communique | Ministerial Decision No. (88) of 2025 | July 2025 Draft Law – Para 16(2) | ||||||||||||||||||||||||||||||||||||||||||||
| 1 | Amendments to QDMTT Safe Harbour for 9.1 | 2025 Tax Amendment Act, Article 3 (10) | Section 1(12) August 2025 Draft Law | 34(2) | 2025 Amendment Law 81 | Schedule 61,part 3, division 4 | Transposed under the 2025 amended law | Finance Bill 2025, Section 92 | Art 5 – December 2025 Amendment Law | December 2025 Executive Decree Amendments (Art 8) | 2025 Draft Bill/Regs | Transposed – Article 2 | Not applicable | July 2025 Draft Law – Para 17(2) | ||||||||||||||||||||||||||||||||||||||||||||||||
| 1 | Article 9.1 of the GloBE Rules | 2025 Tax Amendment Act, Article 3 (24) | Section 1(12) August 2025 Draft Law | 2025 Law, 241 | 51(2)/(7)/(8) June 2025 amendment law | November 2025 Draft Law, Ch9, 1a | 2026 Amendment Law 82/82a | Transposed under Schedule 64 | Transposed under the 2025 amended law. Applies in respect of any Fiscal Year beginning on or after June 17, 2025. | Finance Bill 2025, Section 92 | Art 9 – December 2025 Amendment Law | 14.1 December 2025 Amending Law | 2025 Draft Bill/Regs | October 2025 Amendment Law – § 32 par. 10 to 12 and § 46b | Transposed – Article 2 | 12.3.2.1 Communique | Ministerial Decision No. (88) of 2025 | July 2025 Draft Law – Para 17 | ||||||||||||||||||||||||||||||||||||||||||||
| 1 | Central Record of Legislation with Transitional Qualified Status | Applies OECD Guidance | Transposed under Schedule 64 | Transposed under the 2025 amended law (applies in respect of any Fiscal Year that begins on or after June 17, 2025 and is deemed to have been in operation from the beginning of any Fiscal Year that began on January 1, 2025 or any subsequent day prior to June 17, 2025) | Transposed – Article 2 | Ministerial Decision No. (88) of 2025 | Yes |
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