Hong Kong publishes bill amending preferential tax regimes for funds, family-owned investment holding vehicles, carried interest
The Hong Kong government has published the Inland Revenue (Amendment) (Preferential Tax Regimes for Funds, Family-owned Investment Holding Vehicles and Carried Interest) Bill 2026 in the Gazette on 12 June 2026. The bill aims to enhance the
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Panama enacts law introducing economic substance rules for MNE groups
Panama has enacted Law No. 526 of 28 May 2026, significantly reforming its National Fiscal Code by introducing economic substance requirements for multinational enterprise (MNE) groups earning foreign-source passive income. The reform is designed
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Mozambique enacts 2026 tax reforms, introduces VAT on digital services
Mozambique's President signed into law and ordered the official publication of the Economic and Social Plan and State Budget (PESOE) for 2026, along with a package of tax reform legislation on 29 December 2025. Effective from 1 January 2026, the
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Algeria: 2026 Finance Law revises tax rules for non-residents and PEs, adds green incentives
Algeria's Ministry of Finance has gazetted the Finance Law for 2026 on 31 December 2025. The Finance Law for 2026 sets out the national budget, defining projected revenues, spending limits, and the overall financial framework for state
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US: IRS issues guidance on elimination of one-month deferral for specified foreign corporations
The US Internal Revenue Service (IRS) issued Notice 2025-72 on 25 November 2025, stating that the Treasury Department and IRS plan to issue proposed regulations under section 70352 of the "One Big Beautiful Bill Act" (OBBBA), which repeals section
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Finland: Parliament reviews amendments to permanent establishment income allocation rules
Finland’s Parliament is reviewing draft bill HE 164/2025 vp, which proposes amendments to domestic regulations on attributing profits to permanent establishments on 12 November 2025. The proposal suggests amending the Income Tax Act, the Act on
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US: IRS extends treaty benefits to reverse foreign hybrids subject to branch profits tax
The IRS Chief Counsel ruled that reverse foreign hybrids may qualify for reduced branch profits tax on dividend equivalent amounts attributable to treaty-eligible owners. The US Internal Revenue Service (IRS) Chief Counsel has determined that
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Kazakhstan consults on preferential tax jurisdictions list
The deadline for submitting comments is 6 August 2025. Kazakhstan's Ministry of Finance initiated a public consultation on 22 July 2025 regarding a draft order for jurisdictions with preferential tax regimes. This list impacts tax measures for
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Malaysia issues updated guidance on taxation of Malaysian ships
The Public Ruling updates the tax treatment and shipping income exemptions for qualifying Malaysian residents, replacing the 2012 edition. RegFollower Desk The Inland Revenue Board of Malaysia (IRBM) has issued Public Ruling No. 1/2025 on 15
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Costa Rica sets new rules for tobacco tax calculation
The regulations mandate procedures for calculating taxes on tobacco products to fund social welfare and ensure prior reporting of price and import data. Costa Rica’s tax administration (DGT) has published Resolution No. MH-DGT-RES-0008-2025 in
See MoreFinland: MoF consults on OECD-based PE profit attribution
The deadline to submit comments is 30 June 2025. Finland’s Ministry of Finance has opened a public consultation to amend three key tax laws: the Income Tax Act, the Act on Taxation of Business Income, and the Act on the Elimination of
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US: IRS updates guidance on foreign-derived intangible income deduction
The US Internal Revenue Service (IRS) issued an updated practice unit titled, ‘IRC Section 250 Deduction: Foreign-Derived Intangible Income (FDII) on 24 October 2024. This revision eliminates references to unavailable resources and replaces the
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South Africa releases guide on revised tax rates and levies
The South African Revenue Service (SARS) released an updated version of the Guide for Tax Rates/Duties/Levies (Issue 17) on 29 August 2024. This guide compiles current and historical insights into the various taxes, duties, and levies collected by
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Ireland: Revenue provides guidance on foreign entity classification for Irish tax purposes
On 18 May 2023, the Irish Revenue issued eBrief No. 117/23 to provide guidance on classifying foreign entities for Irish tax purposes. Accordingly, Revenue provides Tax and Duty Manual (TDM) Part 35C-00-02 - Foreign Entity Classification For Irish
See MoreIMF Report Looks at the Economy of Hong Kong SAR
On 8 March 2022, the IMF published a report following discussions with the Hong Kong Special Administrative Region (SAR) of China, under Article IV of the IMF’s articles of agreement. The economy of Hong Kong SAR has undergone a strong
See MoreRussia proposes Tax Policy for 2020 to 2022
On 30 September 2019, the Russian Government submitted the Draft Law to the State Duma. The draft law includes the following measures: The bill aims to change the approach to taxing companies in the digital sector. The draft law recommend that
See MoreTaiwan: MOF issues tax ruling on Taiwan-sourced income of foreign entities
On 26 September 2019, Taiwan’s Ministry of Finance (MOF) released a tax ruling regarding the new method of calculating income source from Taiwan originating from foreign entities amending article 15-1 in accordance with Article 8 of the Income
See MoreSouth Africa: SARS publishes draft IN18 on rebate and deduction of foreign taxes on income
On 12 September 2019, the South African Revenue Service (SARS) published draft Interpretation Note 18 (Issue 4) (IN18) regarding the rebate and deduction of foreign taxes on income for public comment. This interpretation note describes the scope,
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