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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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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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 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,
See MoreTaiwan releases tax ruling regarding calculating Taiwan-sourced income of foreign entities
The Ministry of Finance released a tax ruling regarding the new method of calculating income source from Taiwan originating from foreign companies that import, store, manufacture and deliver goods to domestic and foreign customers. According to the
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