On 10 July 2024, the OECD published its invitation to comment on a draft User Guide for the GloBE Information Return XML Schema, a tool created to facilitate domestic GIR filings, wherever appropriate, and to be the technical format for exchanging GIR information between tax administrations. The deadline to send comments was 19 August 2024.

On 28 October 2024, the European Commission proposed amendments to the EU Directive on administrative cooperation in taxation (DAC9). These changes aim to facilitate the exchange of top-up tax information between Member States and allow MNEs to switch from local to central filing. If adopted by the Council of the EU, the rules would enable MNE groups and large domestic groups to file a single top-up tax information return in one EU Member State instead of multiple filings across different Member States.

On 3 October 2024, the EU Commission decided to refer Cyprus, Poland, Portugal and Spain to the Court of Justice of the European Union for failing to notify measures transposing into national law the Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union.

A notification of the head of a German minimum tax group must be made to the German Federal Central Tax Office (BZSt) until 28 February 2025.

On 15 November 2024, the Polish Act implementing the provisions of the EU global minimum tax Directive into the Polish legal system was signed by the President. The law will introduce IIR, UTPR, and QDMTT. The law generally intends to come into effect from January 1, 2025. Transitional provisions provide for the optional possibility of retroactive application of the provisions of the law from January 1, 2024 (with some exceptions - UTPR rules).

On 18 September 2024, the Portuguese Government submitted to the Parliament the draft legislation for the domestic transposition of the GloBE Pillar Two rules, with request for "priority and urgency". This proposal follows several contacts and feedback at the level of the Large Taxpayers Forum, as well as a public consultation held during the latter half of July 2024.

The proposed regime, presented under Draft Law no. 21/XVI/1.ª, was approved by the Portuguese Parliament on 18 October 2024 and was published in the Portuguese Official Gazette on 9 November 2024.

Law 41/2024 transposes into national legislation Council Directive (EU) 2022/2523 of 15 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups whose annual consolidated revenue is equal to or greater than 750 million euros (Pillar Two Directive).

This new regime, formally designated as the Global Minimum Tax Regime (“Regime do Imposto Mínimo Global” or “RIMG”), follows the model rules developed by the OECD/G20 Inclusive Framework. It introduces a new top-up tax when the effective tax rate of a covered group, in any of its jurisdictions, calculated according to the newly approved rules, is less than 15%.

The Spanish Congress approved the draft law transposing the EU minimum tax Directive on 21 November 2024.