BDO Corporate Tax News

• Australia: The ATO released updated guidance on 4 Nov 2025 confirming that the domestic hybrid mismatch rules will continue to apply despite the implementation of the Pillar Two global minimum tax framework, a clarification relevant for multinational groups navigating both regimes. Consultations have been held on draft legislation that would amend the Pillar Two rules to include the introduction of an equity investment inclusion election, rules on qualified flow-through tax benefits and rules on securitisation entities and on a proposal to exempt MNE groups from filing IIR, UTPR or DMTT returns if no tax is due and certain other requirements are met.
• Austria: Draft legislation published on 16 October would incorporate the OECD administrative guidance published in January and December 2023 and June 2024 into Austria’s Pillar Two legislation and provide for a GloBE information return.
• Bahrain: The Ministry of Finance and National Economy has introduced a fee structure for tax appeals relating to the country’s domestic minimum top-up tax and the tax authorities have published an administrative guide on the rules. See article in this issue. On 12 August, the tax authorities published updated guides on in-scope entities and the advance payment of the DMTT.
• Belgium: Guidance released on 22 October addresses various aspects of Belgium’s implementation of the EU minimum taxation directive directive, including scope, determination of GLoBE income, calculation of adjusted covered taxes, the ETR and top‑up taxes, collection of tax, etc. A draft bill submitted to parliament on 9 October contains technical amendments to Belgium’s Pillar Two legislation, including a requirement for in-scope companies to appoint a general representative who would be responsible for compliance, a new definition of “group,” a reduction of the assessment/tax audit period from 10 to six years and some clarifications. If approved the measures would apply with respect to the QDMTT return due by 30 November
• Bermuda: A public consultation held in September focused on draft legislation that would grant three proposed refundable tax credits: a substance-based tax credit for regulated insurers, a community development tax credit and a utilities infrastructure tax credit.
• Brazil: A Normative Instruction released on 3 October updates the Pillar Two rules to incorporate OECD guidance dating from June 2024 and January 2025 and clarifies areas such as entity classification, fiscal year alignment for CEs, etc.
• Cabo Verde: The 2026 budget contains a proposal to introduce a qualified global minimum tax (to be known as an “IMG”) at a rate of 15% that would apply to CEs in Cape Verde that are members of an MNE group or large national groups with annual revenues of at least EUR 750 million in at least two of the preceding four years. If the ETR of a CE is below 15%, a national qualified top-up tax would be payable, equal to the difference between the 15% IMG rate and the lower ETR of the entities based in Cabo Verde. Applicable rules and procedures will be set out in separate legislation. If the measures are approved by the National Assembly and the president, they will take effect on 1 January 2026.
• Canada: The Department of Finance held a consultation in August and September on draft legislation that would make technical changes to the Global Minimum Tax Act.
• Denmark: The consolidated text of the Minimum Taxation Act, as amended, was published on 10 September and is effective retroactively as from 1 July 2025. The amended act aligns Danish rules with the latest OECD administrative guidance, clarifies the interaction between the minimum tax rules and international joint taxation regime, and addresses the treatment of deferred taxes.
• Finland: A consultation launched on 6 November seeks feedback on proposed amendments to the global minimum tax rules to incorporate OECD guidance issued in June 2024 and January 2025 and to introduce a new anti-avoidance provision. The latter provision would allow the Finnish tax authorities to disallow arrangements designed to avoid the minimum tax but also would allow the authorities to issue advance rulings on minimum tax liabilities. The consultation ends 19 November.
• France: The authorities published their first set of guidance on the global minimum tax rules on 8 October, focusing on definitions relevant to the GloBE rules and the scope and territoriality of the rules, and signals that future guidance on various topics will be forthcoming.
• Germany: On 6 October, the German states voted down a proposal to suspend Germany’s minimum tax, following a request made by several states to suspend the tax until outstanding issues are resolved at the international level, specifically, pending resolution of the US proposal to exempt US companies from most of the Pillar Two system. Draft regulations published on 29 September provide for the implementation of the OECD’s administrative guidance from January 2025 and include a transitional simplified jurisdictional reporting framework that will apply for fiscal years starting on or before 31 December 2028 and ending before 1 July 2030.
• Guernsey: The government has issued its first set of guidance on the Pillar Two legislation, which includes information on the registration process and deadlines, as well as an FAQ.
• Hong Kong: The Inland Revenue Department is sending letters to potential MNE groups to notify them of their compliance obligations (see article in this issue). The IRD also published updated guidance on the minimum tax rules on 17 October, which contains examples of the electronic filing of tax returns.
• Hungary: On 16 October, the tax authorities released a draft version of the form that will be used to declare and pay the advance QDMTT, as well as instructions.
• Iceland: The 2026 budget presented on 8 September 2025 includes the introduction of a 15% global minimum tax based on the EU directive and the OECD model rules. The proposals include an IIR and a QDMTT that would apply to entities that are part of a consolidated group with annual revenue of EUR 750 million or more in at least two of the four preceding financial years. If enacted, the IIR and QDMTT would apply for fiscal years starting on or after 31 December 2025.
• India: India has not enacted Pillar Two legislation but is preparing by setting up a panel to frame appropriate rules.
• Ireland: On 5 September, the Irish tax authorities released detailed guidance on the registration process, confirming that in-scope entities must register with the authorities by 31 December 2025. Penalties will be imposed for noncompliance. The Pillar Two hub and registration portal were launched on 14 August.
• Isle of Man: A notice released on 21 August acknowledges the OECD’s updating of its Central Record of Legislation with Transitional Qualified Status confirming that the IOM’s MTUT is a qualified IIR and the DMTT is a qualified domestic minimum top-up tax with safe harbour status. 
• Israel: The Minister of Finance and the tax authorities published comprehensive draft legislation for a DMTT on 5 October for a short public consultation. The regime would apply to the income of Israeli resident entities that are part of an MNE group with global group turnover of EUR 750 million or more, starting from the beginning of the 2026 tax year. The DMTT is intended to be in line with the OECD GloBE rules. There are currently no plans to adopt an IIR or a UTPR.
• Italy: A decree published on 11 November sets out the filing, reporting and payment obligations related to the application of the top-up tax, taking into account the administrative guidance issued by the OECD in Jan 2025, the model form for reporting and filing of top-up returns and includes guidance on how to complete the GIR form.
• Kuwait: Executive Regulations issued in June interpret and clarify the Pillar Two legislation, define procedures and implementation mechanisms. See article in this issue.
• Kenya: The Kenya Revenue Authority released draft regulations on 3 November that address the operation of the DMTT, as well as compliance obligations, and adopt the OECD safe harbours and administrative guidance.
• Liechtenstein: Parliament approved changes to the GloBE Act on 5 November that enable the exchange of GloBE tax and information returns following a public consultation. The measures will become effective once published in the official gazette.
• Mauritius: A communique issued by the tax authorities on 29 October clarifies and extends the QDMTT filing deadline to 30 November 2025.
• Netherlands: The Tax Plan 2026, released on 17 September 2025, would further amend the Minimum Tax Act 2024 to incorporate the OECD guidance dating from June 2023, June 2024 and January 2025 and make some technical adjustments.
• Nigeria: The Nigeria Tax Act 2025 published on 6 September and that will apply as from 1 January 2026 includes a minimum tax that is aligned with the OECD framework and that will ensure that large MNE groups pay a minimum effective tax rate of 15%. The tax will apply to MNE groups with consolidated annual revenue of at least EUR 750 million (or its equivalent in local currency) and to Nigerian-based entities whose annual turnover exceeds NGN 50 billion, subject to some exceptions. The tax authorities will be issuing guidance for implementation of the new rules. The legislation includes a provision similar to an IIR and a DMTT but no UTPR.
• Poland: A consultation was held in September on the notification and tax return forms.
• Portugal: Measures published on 2 September approve the registration declaration form for the minimum tax and instructions for completion.
• Qatar: Qatar has introduced legislation that implements Pillar Two measures into domestic law, including an IIR and a DMTT. See article in this issue.
• Romania: An ordinance that applies as from 1 September amends Romania’s minimum taxation rules by introducing marketable transferable tax credits and a carry forward mechanism for excess negative tax expense, updates the domestic top-up tax formula, clarifies the requirements for the QDMTT safe harbour and expands the recognition of deferred taxes for non-IFRS filers. The tax authorities launched a consultation on 7 November on proposed forms for making the notification and for filing the GIR, as well as draft instructions and a guide for completing the forms. The consultation runs through 17 November.
• Singapore: Parliament is looking at proposed amendments to Singapore’s Pillar Two rules that would introduce new technical definitions, revise administrative procedures and clarify the treatment of certain structures.
• Slovak Republic: Parliament approved a bill on 21 October that would incorporate the 2024 and 2025 OECD guidance, amend the rules relating to deferred tax liability and include rules for transparent entities and reverse hybrids. The bill still must be signed by the president and published before it can become effective.
• South Africa: The tax authorities announced on 30 October that the implementation of the GloBE registration and notification functionality on the tax authorities’ portal has been rescheduled from December 2025 to 16 March 2026. As a result of this postponement, notifications that would be due before 30 April 2026 are due by 30 April 2026 and GIRs that would be due before 30 June 2026 are due by that date.
• Spain: A Ministerial Order published on 29 October approves three tax forms and confirms the filing deadlines for the Pillar Two-related returns and notifications. See article in this issue.
• Sweden: Draft legislation announced on 15 August would amend Sweden’s Pillar Two rules to incorporate the OECD’s June 2024 guidance into the domestic law, as well as guidance on how income and taxes are allocated between entities in cross-border structures and the treatment of deferred tax assets.
• Switzerland: An ordinance adopted by the Federal Council on 12 September contains measures for the submission of the GIR that will enable the automatic exchange of GIRs between Switzerland’s tax authorities and authorities in other jurisdictions. The ordinance must be signed into law before it can become effective.
• Thailand: A draft bill provisionally approved by the cabinet on 3 September includes the introduction of qualified refundable tax credits under the minimum tax rules. The credits will be provided to promoted companies for investments or expenditures in areas such as R&D, advanced skills development, production efficiency improvement and sustainable investment in an effort to enhance their competitiveness. The tax credits will be able to be used to deduct various tax payments or where promoted companies have remaining tax credits, to claim cash refunds.
• Turkey: A consultation has been held on a draft general communique that contains the implementing rules for the minimum tax, and the tax authorities have released a draft GIR form. The communiqué defines terms, outlines scope and exemptions, and provides guidance on calculating ETRs, determining covered taxes and filing information returns and would incorporate the transitional safe harbour.
• United Arab Emirates: All OECD administrative guidance on the GloBE rules issued up to January 2025 has been adopted.
• United Kingdom: On 15 October, the tax authorities released guidance on other jurisdictions that have implemented Pillar Two top-up taxes and on 1 September, the tax authorities released guidance on registering and reporting on Pillar Two taxes. A comprehensive internal manual published in August sets out the authorities’ position on issues relating to the top-up taxes.
• Uruguay: The Budget Bill for 2025-2029 presented by the government on 31 August would introduce a DMTT (officially known as the domestic complementary minimum tax) designed to be in line with the Pillar Two GloBE rules. If enacted, the DMTT was initially scheduled to apply as from 1 January 2026 but amendments to the bill presented on 30 September would delay the effective date to fiscal years closing as from the date the law is enacted. There currently are no plans to introduce an IIR or a UTPR.
• Vietnam: A decree that became effective on 15 October 2025 and that applies retroactively from fiscal year 2024 provides details on the application of the global minimum tax, in particular, which entities are covered and excluded, as well as notification and registration requirements and the forms that must be submitted.