As Pillar Two enters a new era shaped by the G7 Side-by-Side (SbS) announcement, the role of tax incentives is expected to undergo a significant recalibration as a component to the SbS agreement. Tax incentives are central to how jurisdictions position themselves within the evolving architecture of international taxation and are an important element for multinational enterprise (MNE) investment decisions. Recent statements from G7^[1] and G20^[2] (July and October 2025) reflect a growing intent to revisit how tax incentives are structured and integrated within Pillar Two rules.

Existing Treatment of Tax Incentives

Under the Global Anti-Base Erosion (GloBE) Rules, the classification and subsequent treatment of tax incentives is one of the key elements for determining a jurisdiction’s Effective Tax Rate (ETR). As per the regulations, the tax incentive affects the ETR calculation in one of two ways, either by reducing Covered Taxes (the numerator) or increasing GloBE Income (the denominator). This distinction is key to grasping why some incentives are more valuable than others under a 15% minimum tax regime.

One of the types of tax incentives is Qualified Refundable Tax Credits (QRTCs), which are either payable in cash or refundable within four years. They function like government grants and present a valuable tool for improving the ETR as they affect the denominator of the ETR calculation rather than the numerator. This treatment aligns with financial accounting principles, where the taxpayer’s entitlement to such credits is not contingent upon profitability or income tax liability. Similarly, Marketable Transferable Tax Credits (MTTCs), receive equivalent treatment as QRTCs.

In contrast, all other tax credits such as Non-Qualified Refundable Credits, Non-Refundable Credits and Non-Marketable Credits can only be used to offset actual tax liabilities and are considered reductions to Covered Taxes under the GloBE rules. Similarly, traditional income-based tax incentives such as reduced rates, tax holidays, tax exemptions, and others are also treated as reduction to Covered Taxes. In particular, the nuanced differentiated approach between QRTC and non-QRTC, in the design of tax incentives, under the GloBE framework has raised concerns among governments and businesses alike, considering the more significant impact of the non-QRTCs in the ETR calculations.^[3]

In Focus: Substance-Based Tax Incentives

The G7 SbS announcement had also pledged to revisit the treatment of substance-based, non-refundable tax credits under Pillar Two. This commitment was subsequently reaffirmed and broadened by the G20 in both its communiqué, which emphasized the importance of ensuring fair treatment of substance-based tax incentives within the global minimum tax framework, apparently broadening the scope of the tax incentives to be revisited as to cover all types of incentives linked to substance without being limited to tax credits types of incentives.

Substance-based tax incentives have been gaining relevance as a legitimate and strategically aligned tool for attracting investment. Unlike profit-shifting mechanisms that rely on booking income in low-tax jurisdictions with minimal operational presence, substance-based incentives are directly tied to real business activity. They serve as proxies for economic substance—rewarding enterprises for investing in human capital, infrastructure, and/or productive assets. Typically structured as expenditure-based or production-based reliefs, these incentives are granted in proportion to actual investment or output rather than just profits. Common forms of these incentives include R&D tax credits, clean energy incentives, capital investment allowances, manufacturing- and production-linked benefits, reliefs associated with Special Economic Zones (SEZs), and sector-specific subsidies such as film production credits.

Governments worldwide are increasingly integrating substance-based incentives into their investment promotion strategies. Jurisdictions such as Malaysia and Singapore have already begun to incorporate these principles into their tax regimes, positioning themselves ahead of the curve in adapting to the anticipated direction of international tax reform. This approach is in contrast to profit shifting mechanisms like preferential regimes targeting passive income or patent box regime, which often facilitate base erosion with limited economic engagement. Substance-based incentives are more likely to be viewed as aligned with the spirit and intent of the OECD’s GloBE rules, which reflect a broader policy objective: to encourage real economic contribution—creating jobs, building infrastructure, and boosting domestic production, while remaining compliant with international tax standards.

Anticipated Framework for Substance-Based Tax Incentives

To promote consistency in the treatment of substance-based tax incentives, possible conceptual approaches and structural frameworks may be explored. Fundamentally, three issues need to be considered: (i) the scope of the substance-based tax incentives to be covered; (ii) the mechanism to provide the alignment with the current treatment of QRTCs and MTTCs; and (iii) the implementation of the revised tax incentives framework.

In defining the scope of these incentives, the OECD primary focus is on expenditure-based incentives.^[4] Where appropriate, consideration may also be given to (at least certain types of) production-based incentives. Both of these categories are inherently linked to substantive activities within a jurisdiction. The overarching principle may be the demonstrable connection between the incentive and genuine substance in the relevant jurisdiction. It remains to be seen if the revised framework would also accommodate income-based tax incentives with links to substance. As mentioned earlier, these types of incentives are currently more affected under the GloBE framework and have been viewed by the OECD as less desirable and less favourable to achieve sustainable development goals.^[5]

In what refers to the mechanism to provide alignment with QRTCs and MTTCs, one potential approach is to recognize such incentives as income, increasing the denominator of the ETR formula, similarly to the current treatment of QRTCs and MTTCs. However, the underlying rational for this treatment is that the GloBE rules follow financial accounting by treating cash grants and refundable tax credits as income, something that does not appear to be transposable to other types of incentives. Therefore, the alternative adjustment that appears to be more consistent with the overall GloBE framework is to look to the other side of the ETR formula (the numerator) and allow for an increase in Covered Taxes.

A strictly related issue refers to the need to quantify or limit the adjustment to the jurisdictional ETR. Also, here two possible methodologies may be considered. Adjustments may be based on the actual amount of the incentive utilized during the relevant period, ensuring a direct correlation with economic activity. Alternatively, a substance cap may be introduced to safeguard proportionality and prevent excessive recognition of benefits.^[6] Both approaches aim to strike a balance between incentivizing real economic substance and maintaining the integrity of the ETR computation by prevention of artificial manipulation.

Finally, and regarding implementation, this may occur by introducing a safe harbor regime, designed to accommodate eligible substance-based tax incentives in a manner that reflects their economic relevance, or otherwise by amending the GloBE rules.

Conclusion and Key Takeaways

As global tax frameworks continue to evolve, MNEs should take this opportunity to reassess their incentive strategies in each jurisdiction, acknowledging that the upcoming revised framework will provide better protection to benefits related to tax incentives based on substance. Increased engagement with local authorities, such as Singapore’s Economic Development Board (EDB), will likely become a strategic necessity as jurisdictions recalibrate their offerings in response to new rules and competitive pressures.

At this juncture, adopting a posture of strategic patience is advisable. Premature restructuring of incentive arrangements may introduce complexity or result in missed opportunities as further guidance and consensus emerge. Enterprises should remain agile, allowing for responsive adaptation as clarity unfolds.

Simultaneously, Pillar Two readiness must remain a priority, particularly with the implementation of the SbS system possible from January 1, 2026. A balanced approach, combining strategic patience with proactive readiness, will be essential to navigating impact on structures, shifting incentive regimes and ensuring compliance readiness.

USA

October 1, 2025: US Court of Appeals Limits IRS Authority to Tax Income Blocked by Foreign Law in 3M Case^[7]

The US Court of Appeals for the Eighth Circuit reversed a 2023 Tax Court decision in 3M Company and Subsidiaries v. Commissioner, holding that IRC Section 482 does not authorize the IRS to tax a domestic parent company on royalties it could not receive from a foreign subsidiary. Applying the Supreme Court’s 2024 Loper Bright standard, the Appeals Court ruled that the IRS can only reallocate income over which the taxpayer has "dominion or control." Brazilian law restricted 3M’s subsidiary from paying excess royalties, so the IRS’s allocation was disallowed. This decision limits the IRS’s power under Section 482 to reallocate income restricted by foreign law, reinforcing that agency interpretations cannot override statutory limits.

October 17, 2025: IMO Postpones Proposed Global Carbon Tax Following US Concerns^[8],[9]

On October 10, 2025, the United States rejected the United Nations International Maritime Organization’s (IMO) proposed global carbon tax, known as the Net-Zero Framework (NZF). IMO's NZF is intended to mark the first global tax targeting carbon emissions from international shipping. US has raised concerns over unfair costs to American consumers, shipping companies, and energy providers, and warned retaliatory measures against countries supporting the tax, including port restrictions, visa limitations, and sanctions. Following the opposition from US, the IMO postponed adoption of the tax for at least one year, with talks resuming in 2026.

October 21, 2025: US Treasury and IRS Seek to Simplify FIRPTA Control Tests by Removing Look-Through Requirement^[10]

The Treasury Department and IRS proposed removing the "domestic corporation look-through rule" for determining domestic control of Qualified Investment Entities (QIEs) under Foreign Investment in Real Property Tax Act (FIRPTA). This rule required tracing foreign ownership through certain domestic C corporations, causing legal uncertainty and operational challenges. The proposal treats all domestic C corporations as non-look-through persons, simplifying compliance and aligning with statutory language. The changes would apply to transactions from the publication date, with optional retroactive application from April 25, 2024.

Canada

October 6, 2025: Canada Adopts Capital Budgeting Framework, Shifts to Fall Budget Cycle^[11]

Canada’s government announced a new Capital Budgeting Framework that separates capital investments from day-to-day operating expenses, prioritizing long-term projects like infrastructure and housing. Further, the federal budget cycle of Canada will shift permanently to the fall, starting with Budget 2025, followed by a spring economic and fiscal update. This change aims to improve planning and align budgeting with construction seasons, benefiting governments, investors, and businesses.

Belgium

October 3, 2025: Belgium Issues Circular to Clarify Participation Exemption and Dividend Withholding Tax Rules^[12]

The Federal Service for Finance published a circular on October 3, 2025, clarifying how the recent changes to the participation exemption will operate from assessment year 2026. The key clarifications provided include coverage of “financial fixed asset” as per Companies and Associations Code (i.e., three categories—(1) related companies through control, (2) non-related companies where shareholder can exercises influence, and (3) other holdings maintained to contribute to the shareholder’s own company), exemption for capital gains on shares, and withholding-tax exemption on dividends (payable to non-residents, including cases where a foreign shareholder holds less than 10%, but the acquisition value is at least EUR 2.5 million). Lastly, an anti-abuse rule provides that changes to a company’s financial year-end from February 03, 2025, onward made for tax-avoidance reasons will be disregarded for participation-exemption purposes.

October 9, 2025: Government Brings Bill to Amend Minimum-Tax Law; Clarifies Scope, Joint-Filing and Representative Rules^[13]

The government has tabled the Bill DOC 56 1070/001 to Chamber of Representatives on October 9, 2025, to amend the Law on the introduction of Minimum Tax (LoMT), which implements a 15% minimum effective tax rate for groups with combined revenues above EUR 750 million and a parent or subsidiary in the EU. Among other things, the draft bill abolishes Article 2(2) implying joint filing by group companies rather than individual filings, adds detailed definitions for joint ventures (and exclusions thereof) and reporting group entities, application of joint assessments where multiple entities are in scope, and application of Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR) (including IIR on joint venture or affiliated entities under holding structures).

October 17, 2025: Belgium Seeks to Implement DAC8^[14]

The Council of Ministers has adopted a preliminary draft to implement DAC8 into Belgian law, aiming to include data relating to crypto-asset data into automatic-exchange of information framework and creating a new reporting duty for crypto-asset service providers. The draft has been sent to the Data Protection Authority and the Council of State for opinion.

October 17, 2025: Chamber of Representatives Adopts Bill Extending Tax Exemption to Sister Mergers^[15]

The Chamber of Representatives adopted Bill DOC 56 0654 on October 17, 2025, to broaden the existing tax-neutral merger regime to include sister mergers. The adopted text refers to the cumulative features of a domestic or cross-border sister merger (all assets transferred, dissolution without liquidation of acquired company, same shareholder or identical shareholding proportions, and no issuance of new shares by the acquirer). The measure is included with retroactive effect from June 16, 2023.

October 22, 2025: Belgium Publishes Detailed Circular on Pillar Two Implementation and Administration^[16]

The Federal Public Service (SPF) Finance issued Circular 2025/C/68, published on October 22, 2025, setting out detailed guidance on how Belgium will apply the EU Minimum Taxation Directive and the OECD GloBE rules, including the QDMTT, IIR, and UTPR. The circular explains key definitions and scope, the calculation of GloBE income and adjusted covered taxes, the Effective Tax Rate and top-up tax mechanics, treatment of R&D credits, and transitional CFC issues, effective dates, etc.

October 27, 2025: Belgian Constitutional Court Asks ECJ to Rule on Whether the UTPR Is Compatible With EU Law^[17]

The Constitutional Court referred Case C-519/25 (American Free Enterprise Chamber of Commerce) to the Court of Justice of the European Union, asking whether Articles 12–14 of the Minimum Taxation Directive (the UTPR)—which can make constituent entities in the Union liable for top-up tax on under-taxed profits realized elsewhere in the group—are compatible with articles of the Fundamental Rights Charter, Articles 49 and 56 of Treaty on the Functioning of European Union (freedoms of establishment and services), legal-certainty principles, and fiscal territoriality. The preliminary-ruling request was published in the Official Journal on October 27, 2025.

Austria

October 17, 2025: Ministry of Finance Releases Draft Tax Amendment Act, 2025, for Consultation; Includes DAC9 and Pillar Two Refinements^[18]

The Ministry of Finance has published the draft Tax Amendment Act, 2025, for public consultation, amending multiple existing law. Among other things, the draft proposes DAC9 into domestic law and rules for automatic exchange of GloBE information under the GIR MCAA and amends Minimum Taxation Law, viz.: clarification on definition of fully transparent, hybrid, reverse-hybrid entities; calculations pertaining to deferred tax (including transitional year rules and safe harbors); and additions to allocation of CFC in mixed CFC regime structures. The consultation period ran until November 3, 2025.

Netherlands

October 28, 2025: Netherlands Updates Treaty Withholding-Tax Exemption and Refund Procedures^[19]

Decree No. 2025-20848 was released on October 28, 2025, providing for rules for taxpayers to claim exemption or refunds of withholding tax pertaining to qualifying and portfolio dividends, and on interest, other than under the Netherlands–US Treaty (1992), the Curaçao–Netherlands arrangement (2013), and Inheritance and Gift Tax Arrangement (2013). Key changes include: The special refund route for portfolio dividends is discontinued (refunds must follow the general procedure and require a residence certificate no older than two years); exemption requests for qualifying dividends must state the company’s RSIN; and the Rotterdam APA/ATR team is no longer authorized to decide Curaçao-related qualifying-dividend refunds. The decree also removes legacy transitional provisions on four-year validity of prior decisions and removes the requirement to provide printed forms upon request (which are now freely available on the Tax Administration website), and it replaces the earlier implementing decrees.

October 30, 2025: CJEU Dismisses Appeal Against Pillar Two Directive Citing Lack of Standing^[20]

The Court of Justice dismissed Fugro NV’s appeal and upheld the General Court’s December 15, 2023, order that the company was not individually concerned or a part of the limited class affected by Council Directive (EU) 2022/2523 (the Pillar Two/Minimum Tax Directive), so the action was inadmissible. The dispute turned on Article 17’s shipping-income exclusion and whether beneficiaries of national tonnage-tax schemes formed a limited class. The Court found Fugro failed to show it belonged to such a limited, identifiable class and rejected its argument that the directive unlawfully impaired rights acquired under national tax decisions.

Hungary

October 14, 2025: Government Tables Bill to Implement DAC8 and DAC9^[21]

The Bill No. T/12802 to implement both the DAC8 and DAC9 directives into Hungarian law, dated October 14, 2025, has been presented before the Parliament. The bill seeks to amend Act XXXVII of 2013 on international administrative cooperation in taxation to expand data exchange between tax authorities and extend information-sharing to third countries beyond the EU. It also incorporates Hungary’s commitments under the DPI MCAA, CARF MCAA, and the CRS Addendum signed in 2024–2025 and updates the annexes to the CRS and CbCR MCAA laws to include newly participating jurisdictions.

Italy

October 29, 2025: Italy Issues Decree on GloBE Return Filing and DAC9 Compliance^[22]

Italy gazetted Legislative Decree laying down procedure for filing the GloBE Information Return (GIR) by the in-scope taxpayer. Per an earlier decree issued in March 2025, constituent entities must file their GIR within 15 months after the end of fiscal year (or 18 months for the transitional year, but not before June 30, 2026). The decree aligns with OECD Pillar Two guidance, incorporates the administrative clarifications issued in January 2025, and implements related provisions of DAC9.

Finland

October 9, 2025: Government Proposes Law to Transpose DAC9^[23]

The Government submitted Bill HE 142/2025 to Parliament on October 9, 2025, to implement Council Directive (EU) 2025/872 (DAC9) into Finnish law with effect from January 1, 2026. A consultation on the draft proposal was opened in September 2025.

France

October 8, 2025: French Tax Authority Publishes First Guidance on Pillar Two^[24]

The tax authorities have issued an initial set of guidelines on October 8, 2025, explaining the domestic rules that implement the global minimum tax under Articles 223 VJ et seq. of the General Tax Code. The guidance clarifies core definitions, the scope, and territoriality rules. The tax authorities also announced that further guidance is being drafted to cover: safe harbors, effective tax rate computation, top-up tax calculation, payment and filing requirements, group and reorganization treatment, special regimes, transitional provisions, and audit and collection procedures.

October 14, 2025: Finance Bill Proposes One-Year Extension of Exceptional CIT Surcharge for Large Companies and Introduces a New Tax on Holding Companies^[25]

The Finance Bill submitted on October 13, 2025, proposes to extend, for one year, the Exceptional Corporate Income Tax surcharge that applies to large companies. The extension is presented as a temporary measure and remains subject to parliamentary approval. Further, the draft Finance Bill also includes a new levy targeting holding companies.

Spain

October 29, 2025: Spain Approves Pillar Two Return Models: Forms 240, 241, and 242^[26]

The Ministry of Finance released Order HAC/1198/2025 on October 29, 2025, which approves three new tax-return models for Spain’s complementary Pillar Two regime: Form 240 (notification by the constituent entity filing the informative return of the complementary tax); Form 241 (information return of the complementary tax); and Form 242 (self-assessment of the complementary tax). The Order implements provisions of Law 7/2024 and Royal Decree 252/2025 to align Spanish procedures with the OECD Pillar Two framework.

Malaysia

October 3, 2025: Malaysia Implements Tax Exemption Scheme for Single Family Offices in Forest City Special Financial Zone^{[27], [28], [29], [30], [31], [32]}

Malaysia’s Ministry of Finance gazetted various exemption orders relating to Pulau 1 of Forest City Special Financial Zone. The key features of exemptions, subject to specified conditions, are: a 0% income tax rate for qualifying companies conducting designated activities for a single family for two consecutive periods of up to 10 years each (maximum 20 years); exemption from income tax on gains or profits from the disposal of unlisted Malaysian companies to the qualifying entity; eligibility for industrial building allowance at 10% of capital expenditure on construction or purchase for the relevant year of assessment and the following nine years; exemption from gains on disposals of real property in Pulau 1 by non-citizens and non-permanent residents (from the sixth year onward) and reduced gains tax rates for disposals in the fourth and fifth years; and exemption from stamp duty on instruments transferring assets between a single family fund company and family members or member vehicles.

Singapore

October 14, 2025: Finance (Income Taxes) Bill 2025 Introduced to Update Singapore’s Income Tax and Minimum Tax Rules^[33]

The Finance (Income Taxes) Bill 2025 has been introduced to Singapore’s Parliament, following public consultation, to amend the Income Tax Act 1947 and the Multinational Enterprise (Minimum Tax) Act 2024. The Bill proposes several key changes: a 50% corporate income tax rebate for the Year of Assessment (YA) 2025 (with a minimum SGD 2,000 cash grant for active companies employing at least one local in 2024); expansion of 13W tax exemption to include gains from the disposal of preference shares; enhancement of deductions for employee equity-based remuneration; new incentives for corporate and fund manager listings; and extends or refines various existing schemes, such as the Double Tax Deduction for Internationalization, Mergers and Acquisitions, Land Intensification Allowance, and Maritime Sector Incentive.

Vietnam

October 21, 2025: Vietnam Ministry of Finance Issues New Administrative Procedures for Global Minimum Tax Compliance^[34]

The Vietnam Ministry of Finance has introduced updated administrative procedures and regulatory forms to govern tax compliance under the global minimum tax framework.

Please refer to detailed A&M tax alert^[35] for more information on this.

India

October 17, 2025: Supreme Court Rules Non-Resident Company Can Claim Business Deductions Even Without Contract in India^[36]

The Supreme Court of India, in a judgment dated October 17, 2025, ruled that a French non-resident drilling company is entitled to claim business expenditure and carry-forward depreciation even during the years when it did not have an active contract in India. The tax authorities had denied these claims on the basis that the company was not carrying on business in India during those years. The Court held that a temporary lull in business does not amount to cessation of business, and presence of a permanent establishment in India is not mandatory for considering that business is being carried on for tax purposes.

Israel

October 5, 2025: Israel Unveils Draft Law for Domestic Minimum Tax^[37]

Israel ’s Ministry of Finance and Tax Authority has proposed a Domestic Top-Up Minimum Tax effective January 1, 2026, targeting large multinational groups to ensure a minimum 15% tax rate, in line with OECD Pillar Two. As per the announcement, the Ministry of Finance is conducting extensive staff work aimed at creating a system of incentives that is adapted to the rules of Pillar Two, based mainly on the examination of the Qualified Refundable Tax Credit mechanism, in a way that will enable the State of Israel to maintain competitive advantages and attract international investments. Public comments were invited until October 31, 2025.

Australia

October 1, 2025: The Australian Tax Office Sets Out Framework for Third-Party Debt Deduction Limits^[38]

On October 1, 2025, the Commissioner of Taxation updated his draft guidance on the Third Party Debt Test (TDPT) by publishing: finalized binding interpretative guidance on the TPDT in TR 2025/2 “Income tax: aspects of the third party debt test in Subdivision 820-EAB of the Income Tax Assessment Act 1997”; and a finalized compliance approach to the TPDT in Schedule 3 to PCG 2025/2 “Restructures and the thin capitalization and debt deduction creation rules – ATO compliance approach”.

Please refer to detailed A&M tax alert^[39] for more information on this.

October 21, 2025: Full Federal Court Backs Oracle, Grants Stay in Cross-Border Tax Dispute^[40]

In Oracle Corporation Australia Pty Ltd v Commissioner of Taxation [2025] FCAFC 145, the Full Federal Court ruled in favor of Oracle by granting a stay of domestic proceedings while a Mutual Agreement Procedure (MAP) under the Australia–Ireland tax treaty is pursued. The dispute centres on whether payments made by Oracle Australia to its Irish affiliate for software rights constitute “royalties” subject to Australian withholding tax. The Court emphasized that the MAP mechanism under tax treaties provides an independent and valid route for resolving double taxation issues and that domestic proceedings can be deferred when a taxpayer opts for treaty-based relief.

October 22, 2025: Australian Taxation Office Releases Guidance on Transitional CbCR Safe Harbor^[41]

The Australian Taxation Office has published updated guidance on transitional Country-by-Country Reporting (CbCR) safe harbor. This guidance aims to help taxpayers determine whether the transitional CBCR safe harbor applies and how it may simplify Pillar Two compliance. The updated guidance provides an overview of the transitional CbCR safe harbor, outlining eligibility conditions, its impact when applied, and the applicable transition period. It explains how to use the three safe harbor tests: de minimis; simplified effective tax rate; and routine profits. Further, it offers details on acceptable data sources, including qualified CbC reports and qualified financial statements, for applying these rules.

October 27, 2025: Australian Treasury Seeks Feedback on Amendments to Global and Domestic Minimum Tax Rules^[42]

The Australian Treasury has released a consultation paper proposing amendments to the 15% minimum tax framework introduced in 2024 for large multinational groups. The proposed changes aim to ensure closer alignment with the OECD’s GloBE rules. Key updates include elections for equity investments, treatment of qualified flow-through tax benefits, new rules for regulated mutual insurance companies, and specific provisions for securitization entities. Public submissions are open until November 21, 2025.

New Zealand

October 6, 2025: Inland Revenue Issues Guidance on Taxation of Gains and Staking Rewards From Crypto Assets^[43]

In a recent non-binding technical decision summary, New Zealand's Inland Revenue (IR) clarified that gains from disposing of crypto assets are taxable as income when the taxpayer's dominant purpose is profit-making through buying and selling, rather than long-term holding for staking rewards. The IR found that taxpayers conducting coordinated trading activities with a plan to generate profits are carrying on a profit-making scheme. Staking rewards are treated as ordinary income rather than capital gains, because they are regularly received, convertible to money, and represent a return on investment.

• The United States finalized reciprocal trade agreements with Malaysia and Cambodia, maintaining a 19% tariff on most goods while exempting select products, and both countries agreed to eliminate or reduce tariffs on certain US exports and remove digital services taxes discriminating against US companies. ^{[44], [45]}
• The US also announced framework deals with Vietnam and Thailand, keeping tariffs at about 20% and 19%, respectively, with commitments to reduce non-tariff barriers.^{[46], [47]}
• The United States and Japan implemented the July 2025 Trade Deal on October 28, 2025, that sets US tariffs on Japanese imports at 15%.^[48]