On 22 October 2025, Belgium’s Federal Public Service Finance issued the Circular Letter 2025/C/68 providing extensive administrative guidance on the Belgian minimum tax regime for multinational enterprise (MNE) groups and large domestic groups.

On September 2 2025, the Czech Republic, through its President, signed and had published in the Official Gazette an amendment to the Act on Top-Up Taxes, which implements the EU Minimum Tax Directive.

The Danish parliament approved Bill L 194A on 3 June 2025, including amendments to the Minimum Taxation Act, the Corporate Tax Act, the Tax Control Act, and various other Acts. The legislation provides for the implementation of the OECD Pillar Two administrative guidelines issued in June 2024 and January 2025 under the Minimum Taxation Act.

On 9 October 2025, the French tax administration published its first BOFiP guidance on the implementation of Pillar 2, largely reflecting OECD commentary without adding specific French clarifications. The guidance addresses definitions, scope, excluded entities, and territoriality of the 15% minimum tax introduced by the 2024 Finance Act for multinational and domestic groups with consolidated turnover exceeding €750 million. We note that with respect to groups required to prepare combined financial statements, it is accepted that these combined financial statements are deemed to constitute the group’s consolidated financial statements.

Irish Revenue has updated its Pillar Two guidance and launched the registration portal on ROS, which has been open since 15 August 2025. All Irish entities within scope of the IIR, UTPR, or QDMTT must register on an entity-by-entity basis via ROS within 12 months of the end of their first in-scope fiscal year (excluded entities do not need to register), providing group information as required by section 111AAH TCA 1997. For QDMTT, a designated group filer can submit the return for group members and pay the total top-up tax.

Italy has issued two measures on administering the Pillar Two top-up tax. The Deputy Minister of Economy and Finance’s decree of November 7 2025 sets out detailed rules for filing the GloBE tax return and paying the top-up tax due in Italy. Resolution No. 63 of November 10, 2025 specifies the tax codes to be used on the F24 payment form for top-up tax payments.

On 24 July 2025, the Luxembourg government submitted Draft Law No. 8591 to parliament. The bill transposes Directive (EU) 2025/872 and implements the OECD/G20 Inclusive Framework’s multilateral agreement on the automatic exchange of GloBE Information Returns. It also amends the existing Pillar Two Law of 22 December 2023 to align with recent OECD administrative guidance.

On 16 September 2025, the Dutch government released the 2026 Tax Plan, including a Draft Bill to amend the Dutch Minimum Tax Act 2024 (Pillar Two), introducing technical changes and incorporating additional elements of the OECD/G20 Inclusive Framework administrative guidance not previously implemented. Most measures have retroactive effect from 31 December 2023 and apply to fiscal years beginning on or after that date, while the remaining measures take effect on 31 December 2025.

Ordinance No. 290/2025/1 of 2 September, published in the Official Gazette, approves Registration Form 62 and the accompanying instructions for the Portuguese Pillar Two regime (Regime do Imposto Mínimo Global, RIMG), which was established by Law No. 41/2024 of 8 November.

This form is intended for the fulfilment of the obligation to register constituent entities located in Portugal by enterprise groups subject to the aforementioned regime, as well as to notify the commencement of the regime’s application to large-scale domestic groups and multinational enterprise groups in the initial phase of international activity.

Following adoption by the European Council on 14 April 2025, amendments to the European Directive on Administrative Cooperation (DAC9) were published in the Official Journal of the EU on 6 May 2025. On 21 October 2025, the National Council approved legislation amending the Pillar Two rules to implement DAC9 and to align with OECD/G20 administrative guidelines.

Spain has formalized the compliance framework for the new Pillar Two global minimum tax regime. In line with the EU Pillar Two Directive, Spain’s Law 7/2024 established a 15% Complementary Tax for large multinational and domestic groups. Building on this, the Ministry of Finance has approved the official tax returns to implement Pillar Two reporting and payment obligations in Spain; Order HAC/1198/2025 was published in the Official Gazette on 29 October 2025.