US: IRS, Treasury propose new foreign source Section 951A income, FDDEI deductions rules
The US Internal Revenue Service (IRS) and Treasury Department have issued a notice of proposed rulemaking titled Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income, published in
See MoreItaly confirms single economic zone tax credit for pre-notification leased equipment
The Italian Revenue Agency announced the issuance of Response no. 169 on 3 September 2026, in which it ruled that companies operating within the Single Economic Zone (ZES Unica) can claim the regional tax credit for equipment leased in 2026 even
See MoreFinland proposes reduced corporate tax rate in 2027 budget
Finlandโs government has announced the 2027 budget proposal, on 1 September 2026, with the intention to stimulate the economy through targeted tax cuts for low- and middle-income earners and a significant reduction in the corporate tax rate to
See MoreUS: IRS expands Section 45Q safe harbour to cover EOR projects and recapture calculations
The US Internal Revenue Service (IRS) has issued Notice 2026-50, expanding and extending the safe harbour previously established under Notice 2026-1. This administrative notice establishes an updated safe harbour for taxpayers claiming the Section
See MoreFrance expands tax credit for international film, TV productions
The European Commission has approved changes to Franceโs tax credit for foreign film and audiovisual productions, with the State aid authorisation published in the Official Journal of the European Union on 29 July 2026. The reform expands the
See MoreFrance updates guidance on temporary corporate income tax surtax for large companies
The French tax authority has published updated guidance on the temporary corporate income tax surtax for large companies, reflecting the extension and revised liability threshold introduced under the Finance Law for 2026. This official tax
See MoreNigeria launches application guidelines for tax credit on priority sector investments
The Nigerian Investment Promotion Commission has published the Application Guidelines for the Economic Development Tax Incentive (EDTI). The EDTI serves as a comprehensive guide for companies seeking to leverage tax credits for priority
See MoreIreland: EU approves expanded digital games tax credit to cover post-release content
Ireland's Department of Finance has announced on 28 July 2026 that the European Commission has approved the expansion of the Digital Games Tax Credit. As announced in Budget 2026, the 32% tax credit has been extended until 31 December 2031 and
See MoreCanada consults transfer pricing documentation amendments, various other tax measures
Canada's Department of Finance has released draft legislative proposals for public consultation on 23 July 2026 to implement a range of previously announced tax measures, along with other technical amendments to the country's tax
See MoreHungary: NAV cuts corporate allowances and tax types to meet RRF commitments, scraps trust and foundation tax exemptionsย
Hungaryโs government has submitted Draft Law T/387 to the parliament on 17 July 2026 to implement commitments under the Recovery and Resilience Facility (RRF) plan by August 31, 2026, alongside other government programs. This legislative
See MoreUS: California tax credit cap threatens to reverse film industry job gains
California introduced a cap on film and television tax credits that threatens to reverse one of the state's rare recent industrial wins. SB 122, part of the 2025-2026 budget deal, limits annual claims to USD 5 million through 2029. Starting in
See MoreItaly confirms transition 4.0 tax credits survive corporate restructuring if business continuity is maintained
Italyโs Revenue Agency has issued Response no. 139 on 10 July 2026, confirming that companies undergoing severe corporate restructuring do not automatically forfeit their Transition 4.0 tax credits. The ruling emphasises that the true deciding
See MoreNorway removes temporary tax priority exemption in restructuring cases
On 9 June 2026, the parliament adopted new rules on reconstruction in the Bankruptcy Act. The rules will replace the temporary Reconstruction Act when they enter into force. The announcement was made by the Norwegian government in a Ministry of
See MoreUS: Judge blocks Trump-era restrictions on clean energy tax credits
A US federal judge has overturned a Trump administration policy that had tightened requirements for renewable energy developers to claim federal tax incentives. US District Judge Colleen Kollar-Kotelly ruled on Saturday, 6 June 2026, that the
See MoreBrazil: RFB issues guidance on PIS/Cofins credits during CBS transition
Brazilโs tax administration, the Federal Revenue Service (RFB) has clarified on 3 June 2026 that existing PIS/Pasep and Cofins tax credits will remain valid and usable even after these contributions phase out with the introduction of the
See MoreMalaysia: IRBM issues revised guidance on bilateral, unilateral foreign tax credits
The Inland Revenue Board of Malaysia has issued Public Ruling No. 3/2026 on 22 May 2026, guiding the application of bilateral and unilateral tax credits where a Malaysian tax resident is subject to taxation in both Malaysia and a foreign
See MoreUS: JCT publishes detailed explanation of tax overhaul under One Big Beautiful Bill Act
The US Congress Joint Committee on Taxation (JCT) published, on 28 May 2026, its General Explanation of the Tax Provisions of Public Law 119-21, providing a detailed breakdown of the tax measures contained in the One Big Beautiful Bill Act. The
See MoreCanada: CRA releases updated 2025 corporate income tax guide
The Canadian Revenue Agency (CRA) has issued an updated corporate income tax guide for tax year 2025 on 28 May 2026. The guide covers the following: Accelerated capital cost allowance (CCA) for liquefied natural gas (LNG) facilities The
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