[World Tax News] Australia Aligns Minimum Tax Rules With OECD Guidance

Editorial Team – [2026] 182 taxmann.com 381 (Article)

World Tax News provides a weekly snippet of tax news from around the globe. Here is a glimpse of the tax happening in the world this week:

1. Australia aligns global and domestic minimum tax rules with OECD guidance

Australia has issued the Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2025 Measures No. 1) Rules 2025, published on 5 January 2026, which amend certain provisions of the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024.

The changes are intended to ensure continued alignment with administrative guidance issued by the Organisation for Economic Co-operation and Development (OECD). The amendments:

• clarify the limited circumstances in which Securitisation Entities may be subject to top-up tax under the Undertaxed Profits Rules (UTPR);
• introduce an Equity Investment Inclusion Election, together with the related framework governing Qualified Flow-through Tax Benefits;
• make targeted, technical refinements to the Domestic Minimum Tax (DMT) provisions; and
• provide further clarification on the Investment Entity Transparency Election as it applies to Regulated Mutual Insurance Companies.
These amendments apply to fiscal years beginning on or after 1 January 2024.

Source- Federal Register of Legislation

2. Peru extends enhanced tax deductions for scientific research and innovation

Peru has enacted Law No. 32539 of 31 December 2025, extending the incentives originally introduced under Law No. 30309 for the promotion of scientific research, technological development, and technological innovation, as subsequently amended by Law No. 31659.

As previously provided, Law No. 31659 increased the level of incentives and extended their applicability until 31 December 2025. These incentives take the form of enhanced tax deductions for eligible taxpayers incurring expenses on qualifying research and innovation projects.

For qualifying taxpayers whose net income does not exceed 2,300 tax units (UIT), the following deductions apply:

• 240% deduction (i.e., an additional 140%) where the project is carried out directly by the taxpayer or through scientific research, technological development, or technological innovation centers domiciled in Peru; and
• 190% deduction (i.e., an additional 90%) where the project is carried out through such centers not domiciled in Peru.
For qualifying taxpayers whose net income exceeds 2,300 UIT, the deductions are as follows:
• 190% deduction (i.e., an additional 90%) where the project is carried out directly by the taxpayer or through centers domiciled in Peru; and
• 160% deduction (i.e., an additional 60%) where the project is carried out through centers not domiciled in Peru (increased from 150%).

In all cases, the additional deduction of 140%, 90%, or 60% is subject to an annual cap of 500 UIT.

Under Law No. 32539, the applicability of these incentives has now been extended so that the additional deductions may be claimed for qualifying expenditure incurred up to 31 December 2028. Where qualifying expenditure is incurred by that date but the relevant project continues beyond it, the additional deduction may still be applied until 31 December 2030. The law further provides that if a project is not completed within the prescribed timeframe or fails to meet its stated objectives, the taxpayer is required to amend its annual tax returns and, where applicable, pay the resulting tax liability together with interest and penalties.

Note: The value of the tax unit (Unidad Impositiva Tributaria – UIT) for 2026 is PEN 5,500.

Source- Law No. 32539

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