Central filing does not remove local Pillar Two obligations.

Ireland will amend its Pillar Two legislation for the OECD side-by-side package, including new safe harbours. The detail and start date will be in the Finance Bill. CGT falls to 31 per cent.

Germany has ratified the GIR exchange agreement, South Africa requires a GMT03 declaration even where the return is exchanged, and Mauritius's QDMTT has transitional qualified status.

The proposed CORE levy applies entity by entity and branch by branch to EU companies and permanent establishments with net turnover over EUR 100 million. The Commission is reported to be considering changes.

The Full Federal Court held that a gain assessed in the wrong year can still be assessed in the right one. The later year needs its own objection or a request to lodge a late objection.

Ireland presented Budget 2027 on 6 October 2026. Ireland's Pillar Two legislation will be amended to give effect to the OECD side-by-side package, including a number of new safe harbours, and to reflect further OECD administrative guidance and filing requirements. The detail, including the start date, will be in the Finance Bill. Other measures relevant to groups include a cut in the capital gains tax rate from 33 per cent to 31 per cent for disposals on or after 7 October 2026 (development land stays at 33 per cent), an extension of the knowledge development box to 1 January 2032 with a time-limited option for existing claimants to elect out, and R&D tax credit changes: the limits on subcontracting to universities, institutes of higher education and unconnected third parties rise to 20 per cent and EUR 200,000, the first-year payment threshold rises from EUR 87,500 to EUR 105,000, and qualifying expenditure can be increased by 5 per cent of qualifying R&D payroll costs, subject to limits.

Groups with Irish entities should watch the Finance Bill for the start date and the conditions attached to each safe harbour, which will decide whether they are useful. It would be sensible to wait for that text before modelling. Groups planning disposals of Irish assets should note that the Revenue Commissioners are already applying the lower CGT rate to disposals on or after 7 October 2026.

Germany's ratification of the Multilateral Competent Authority Agreement on the Exchange of GloBE Information, dated 30 September 2026, was published in the Federal Law Gazette on 5 October 2026. The date the agreement takes effect for Germany will be announced in the Gazette. South Africa has introduced a new global minimum tax declaration, GMT03, which a foreign filing entity must submit on behalf of a South African entity even where the GloBE information has already been filed in another jurisdiction and exchanged with the South African Revenue Service. The declaration generates the local payment reference number, and the Service may ask for clarification where local data differs from the exchanged data. Mauritius announced on 22 September 2026 that its domestic minimum top-up tax attained transitional qualified status on 10 September 2026, with effect from its start date (the year of assessment beginning 1 July 2025), and its Revenue Authority has released a guide on scope, computation, filing and payment. The status lasts until the OECD completes a full legislative review. In Belgium, the parliamentary Finance and Budget Committee adopted the bill implementing DAC9, which governs exchange of the GloBE information return within the EU, on 2 October 2026; a plenary vote is next.

The common point is that central filing of the GloBE information return does not remove local obligations. Groups with South African entities should allow for GMT03 in the filing calendar, and groups relying on exchange into Germany should confirm the exchange relationship is in effect for the relevant year before relying on a filing made elsewhere.

Argentina's General Resolution 5903, published on 30 September 2026, applies from 1 October 2026 and replaces General Resolutions 4717, 4733, 4759, 5010 and 5798, which continue to apply to tax years that began before that date. The Local File threshold rises to ARS 3 billion of related-party transactions in total or ARS 600 million per transaction (previously ARS 150 million and ARS 15 million), and the Master File threshold rises to group revenue of ARS 500 billion (previously ARS 100 billion), together with related-party transactions of ARS 3 billion in total or ARS 600 million per transaction. The Local File is due in the seventh month after year end and the Master File in the twelfth month. Downward adjustments are not permitted except under a mutual agreement procedure. A new safe harbour allows a markup of at least 5 per cent where the Argentine entity provides low value-adding services, and no more than 5 per cent where a related non-resident provides them, subject to conditions including that the services are no more than 10 per cent of the local entity's operating expenses or income and that, where the local entity is the tested party, it has no operating loss and is not undergoing a business restructuring. A foreign tested party may now be used in limited cases.

For calendar year taxpayers the new rules first apply to the 2027 tax year, so 2026 is still governed by the old resolutions. From then, many groups with smaller Argentine operations may fall below the Local File thresholds, although a Local File is still required, whatever the thresholds, where the Argentine entity is a member of a group that files a country-by-country report. Groups with Argentine service flows should check whether the 5 per cent safe harbour fits their charging model, and note that the bar on downward adjustments may affect year-end true-ups from that year.

In Sunna v Commissioner of Taxation [2026] FCAFC 133, delivered on 1 October 2026, the Full Federal Court (Hespe, Stellios and Wheatley JJ) dismissed both the taxpayer's appeal and the Commissioner's cross-appeal. The taxpayer contracted to sell a Sydney property on 28 June 2019 but did not return the gain in the 2019 year. Instead he returned part of it in the 2020 year, when the deposit was received, and part in the 2023 year, when the sale settled. After an audit, the Commissioner amended the 2019 assessment under section 170(10AA) of the ITAA 1936 to include the whole gain, since CGT event A1 happens when the contract is entered into (section 104-10(3) of the ITAA 1997), issued the 2023 assessment with no capital gain, and amended the 2020 assessment to remove the gain returned in that year. The Court held that an incorrect assessment in one year does not require tax to be assessed incorrectly in another year, and that section 350-10 of Schedule 1 to the TAA (notices of assessment as conclusive evidence) does not extend to the underlying taxable facts. It also held that section 170(10AA) did not authorise the amendment to the 2020 assessment, which was otherwise out of time.

In practical terms, the taxpayer is exposed to tax on the amount returned in 2020 as well as on the full gain in 2019, unless the 2020 assessment is corrected. The Court said the way to correct it was for the taxpayer to request an extension of time to object to the 2020 assessment, and recorded the Commissioner's concession that it would not be legally reasonable to refuse that extension once the 2019 tax was paid. Where a CGT event or other item is found to belong to an earlier year, it would be sensible to protect the later year at the same time, by objection or a request to lodge a late objection, rather than assuming the later year will be corrected.

In July 2025 the Commission proposed the Corporate Resource for Europe (CORE), one of five new own resources to help fund the 2028 to 2034 EU budget. It is an annual lump sum, not a percentage of profit, payable by EU tax resident companies and EU permanent establishments of non-EU companies with net turnover of more than EUR 100 million. The amounts are EUR 100,000 for turnover over EUR 100 million and under EUR 250 million, EUR 250,000 from EUR 250 million to under EUR 500 million, EUR 500,000 from EUR 500 million to under EUR 750 million, and EUR 750,000 at EUR 750 million or more. Government bodies (other than state-owned enterprises), international organisations and non-profits are excluded. The Commission expects it to raise around EUR 6.8 billion a year on average. New own resources need the agreement of every member state, and several, including Germany, the Netherlands, Luxembourg and Austria, are reported to have concerns. On 7 October it was reported that the Commission is considering changes to CORE to raise more from large companies, including big tech, as an alternative to a separate digital tax. Nothing has been formally changed yet.

The proposal applies entity by entity and branch by branch, not at group level, so a group with several EU entities over the threshold could make several payments, and a mid-size EU hub just over EUR 100 million would feel it most. It is not an income tax, so it is unlikely to be a covered tax for Pillar Two or to count for a foreign income tax offset. Deductibility needs care, particularly for an EU branch whose income is non-assessable non-exempt under section 23AH of the ITAA 1936. The Commission is aiming for 2028, although the proposal would allow CORE to start from the 1 January after the decision comes into force, once unanimity and national approvals are obtained, and the design may still change. Groups with large EU subsidiaries or branches may want to list the entities that would be in scope and consider whether the cost could be recharged within the group.

Pereira Consulting is an independent tax advisory practice founded by Neil Pereira, advising multinational groups operating into and out of Australia on international tax, Pillar Two readiness, transfer pricing, anti-avoidance, ATO disputes and corporate income tax compliance. Neil is a Chartered Tax Adviser, Registered Tax Agent and Solicitor.

Disclaimer. This newsletter is general information only and does not constitute tax or legal advice. It is current as at the issue date. Pereira Consulting accepts no liability for any decision made in reliance on its contents. Please contact Neil Pereira to discuss the application of these developments to your specific circumstances.