Scope and computation changes
The note adds the January 2026 Side-by-Side package and updated administrative material to the introductory references. Computation revisions include flow-through reference entities, portfolio-equity matters, qualifying foreign credits, deferred-liability recapture and reverse-hybrid tax allocation. It also clarifies additional current top-up amounts arising from more than one prior year. These changes affect different calculation stages, so updating the headline minimum tax rate alone would not bring an older worksheet into line with the new slides.
Transition, safe harbours and structures
The note identifies changes to transition-year definitions and exclusions for certain pre-regime deferred-tax assets. Related safe-harbour revisions address simplified ETR adjustments, securitisation entities and QDMTT disqualification. Restructuring and tax-neutrality modules receive clarifications on demergers, multi-parent groups, relevant owners and permanent-establishment income allocation. Use this short document as an update index to the substantive modules, not as a replacement for their conditions or the legislation.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
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