Find the Pillar Two rules and filing requirements that apply to your group.

Curaçao published the Landsverordening minimumbelasting 2024 in P.B. 2026 no. 231 on 22 October 2026. The ordinance is dated 13 October. Article 1.1 imposes an income inclusion top-up tax under Chapter 4; Chapters 3 (domestic top-up tax) and 5 (UTPR) are reserved. The final instrument therefore differs from the December 2024 draft, which included a domestic minimum tax.

Article 17.1(1) gives the ordinance effect from 1 January 2025 for fiscal years beginning on or after that date, subject to its specific commencement provisions. Publication in October should be distinguished from the financial years to which the law applies. Official Gazette, Articles 1.1, 4.1 and 17.1; reserved Chapters 3 and 5.

On 26 October 2026, Hong Kong’s Inland Revenue Department launched top-up tax return filing and electronic assessment-notice functions in the Pillar Two Portal. Part 4AA entities of in-scope MNE groups can now file returns for fiscal years beginning on or after 1 January 2025 and view and download their top-up tax assessment notices.

This extends the earlier notification service. IRD’s updated guidance identifies BIR82 as the electronic top-up tax return and says assessed entities, including designated paying entities, need dedicated Business Tax Portal accounts when the return is filed; assessment notices and payment vouchers are electronic. The announcement concerns operational filing facilities, rather than a new tax or filing extension. IRD announcement, 26 October; updated compliance and portal guidance.

Cyprus’s Tax Department notice of 27 October 2026 sets 30 November 2026 for returns T.D.336 and T.D.335, notifications T.D.332 and T.D.334, communications T.D.331 and T.D.333 (all 2026 forms), and payment of top-up tax due. It concerns Cypriot constituent entities and joint ventures for the first fiscal year beginning between 31 December 2023 and 30 December 2024.

Where a listed filing or payment was due earlier, the notice provides relief from administrative penalties, interest and charges if it is completed by and including 30 November. The relief is limited to the specified first-year obligations; it does not waive tax or make every form applicable to every entity. Tax Department notice, 27 October 2026.

On 23 October 2026, Italy’s Revenue Agency published Response No. 188/2026 on the €750 million global minimum tax scope test. The lower 2023 comparative revenue presented after adopting OIC 34 cannot replace the figures in the originally approved 2023 consolidated accounts when testing the group’s position for 2024.

Our analysis considers the accounting background, the limits of the ruling and practical controls for reviewing historical revenue figures.

The Belgian Chamber of Representatives adopted Bill 56 1719 on 22 October 2026 and submitted it for royal assent. The plenary-adopted document, 1719/004, pages 1–2 confirms that the text is identical to the committee version previously covered.

The adopted operative text retains the DAC9 GIR exchange framework and Article 19’s replacement of the QDMTT return deadline with the last day of the fifteenth month after year-end, or the eighteenth month for fiscal years beginning no later than 31 December 2024. Article 24 provides for entry into force on publication in the Belgian Official Gazette. Parliamentary passage and submission for assent do not establish Gazette publication or commencement. See our existing analysis of the bill.