News
Germany Issues Draft Regulation Listing Jurisdictions With Qualifying Pillar Two Status
On April 8, 2026, Germany issued a Draft Regulation listing jurisdictions with qualifying status for the IIR, UTPR, QDMTT and QDMTT Safe Harbour, providing administrative clarity for German MNE groups operating internationally.
Switzerland Issues Communications Implementing OECD January 2025 and 2026 Administrative Guidance
On April 7, 2026, the Swiss Federal Tax Administration issued Communications 030-E-2026 and 031-E-2026, applying the OECD's January 2025 and January 2026 Pillar Two Administrative Guidance to the Swiss domestic regime.
OECD Publishes Third Batch of Updated Transfer Pricing Country Profiles
The OECD released the third batch of updated transfer pricing country profiles on January 16, 2026, covering hard-to-value intangibles and simplified distribution rules for additional jurisdictions.
OECD Inclusive Framework Agrees Side-by-Side Package on Pillar Two
The Inclusive Framework on BEPS reaches agreement on a Side-by-Side system that exempts US-headquartered MNE groups from certain Pillar Two top-up taxes for fiscal years beginning on or after January 1, 2026.
GILTI Renamed to NCTI Under One Big Beautiful Bill Act; Effective Rate Reset for 2026
The One Big Beautiful Bill Act of 2025 renames Global Intangible Low-Taxed Income to Net CFC Tested Income, modifies the Section 250 deduction, and resets the effective US tax rate on the inclusion for tax years beginning after December 31, 2025.