South Africa proposes SEZ transfer pricing reforms, corporate tax changes in Medium-Term Budget Policy
South Africa’s National Treasury has delivered the Medium-Term Budget Policy Statement (MTBPS) to Parliament on 21 October 2026. This package comprises three key amendment bills designed to implement the government's tax policy, monetary
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Uruguay updates dividend withholding tax rules
Uruguay has published Decree No. 427/026 of 1 October 2026, introducing rules for withholding tax on dividends and profits under Budget Law No. 20.446 of 16 December 2025. The decree amends Decree No. 149/007 of 26 April 2007, which regulates the
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Czech Parliament opposes key elements of EU Taxation Omnibus proposal
The Committee on European Affairs of the Czech Chamber of Deputies adopted Resolution No. 106 during its 13th session on 17 September 2026, issuing a formal Reasoned Opinion on the European Commission's proposal for a Taxation Omnibus Directive
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Taiwan urges enterprises to submit audited CFC statements on time
Taiwan's National Taxation Bureau of the Central Area, under the Ministry of Finance, has reminded profit-seeking enterprises that have been granted an extension to submit financial statements of their controlled foreign company (CFC), audited and
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Chile: SII clarifies OIT and tax basis rules for foreign foundation restructuring
Chile’s tax administration, the Servicio de Impuestos Internos (SII), has clarified the Chilean tax consequences of a proposed restructuring involving a Panamanian foundation and its underlying foreign investments. In Ruling No. 2191 of 2026,
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US: Treasury, IRS propose regulations to reshape CFC income inclusion rules among US shareholders
The US Treasury and the IRS have proposed regulations (REG-115646-25) establishing rules for allocating a controlled foreign corporation’s (CFC) subpart F income, tested income, and tested loss among US shareholders based on their respective
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Lithuania: VMI clarifies rules on foreign tax deductions
Lithuania’s State Tax Inspectorate (VMI) has updated its official commentary on the Law on Corporate Income Tax, clarifying how corporate income tax or an equivalent tax paid abroad can be deducted from Lithuanian corporate income tax. The
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Lithuania updates corporate tax guidance on CFC control, PE, group definitions
The Lithuanian State Tax Inspectorate (VMI) updated the commentary to the Law on Corporate Income Tax on 19 August 2026, with changes concerning several definitions under Article 2 of the Lithuanian Corporate Income Tax Law (PMĮ). The guidance
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US: Treasury, IRS consults CFC election to simplify Section 987 foreign currency rules
The US Department of the Treasury and the IRS have initiated a public consultation regarding proposed regulations (REG-103844-26) allowing controlled foreign corporations (CFCs) to elect not to compute or recognise foreign currency gain or loss
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Lithuania: VMI clarifies CFC taxation rules in updated guidance
Lithuania’s State Tax Inspectorate (VMI) updated its guidance on the Law on Corporate Income Tax on 11 August 2026. The guidance details the official commentary and legal amendments regarding the taxation of positive income from controlled foreign
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Korea (Rep.) updates Pillar Two, CFC rules among other measures in 2026 Tax Reform Plan
Korea (Rep.)'s Ministry of Economy and Finance (MoEF) has unveiled its 2026 Tax Reform Plan, proposing a broad package of tax measures aimed at strengthening domestic manufacturing, supporting innovation, expanding tax relief for households and
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Taiwan reminds businesses of documentation requirements for CFC FVPL tax deferral election
Taiwan's Ministry of Finance, in a notice on 4 August 2026, has reminded enterprises that elect to defer the recognition of unrealized gains and losses from fair value through profit or loss (FVPL) financial instruments held by their Controlled
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Australia updates GloBE minimum tax provisions on CFC interaction, deferred tax assets, flow-through entities
Australia has issued the Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2026 Measures No. 2) Rules 2026 (the Amending Rules), introducing minor amendments to the Taxation (Multinational—Global and Domestic Minimum Tax) Rules
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Taiwan clarifies CFC exemption criteria under anti-avoidance rules
Taiwan’s National Taxation Bureau of the Northern Area (NTBNA) has reiterated, on 28 July 2026, the key exemption criteria under the country’s Controlled Foreign Company (CFC) regime, urging businesses to ensure compliance with the rules when
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Netherlands updates hybrid mismatch guidance with new rules on US tax regimes, permanent establishments
The Netherlands published the Hybrid Mismatch Policy Decision 2026 (Decree No. 2026-12123), issued by the State Secretary of Finance on 24 July 2026, replacing the previous policy decision that was originally issued in 2021 and subsequently updated
See MoreNetherlands: CFC levy cannot offset low-tax free investments under participation exemption
The Dutch Tax Administration issued a clarification on 21 July 2026, explaining that the controlled foreign company (CFC) levy does not take low-tax-free investments into account. The recent clarification by the Dutch Tax Administration provides
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European Commission releases final report on ATAD evaluation
The European Commission has published its final evaluation report on the Anti-Tax Avoidance Directive (ATAD) on 25 June 2026, covering the period from 1 January 2019 to mid-2025. The report assesses the effectiveness of ATAD in meeting its
See MoreTaiwan clarifies CFC loss deduction filing, documentation requirements
Taiwan’s National Taxation Bureau of Taipei, Ministry of Finance, stated that the Controlled Foreign Corporation (hereinafter referred to as CFC) system has been in effect since 2023. Profit-seeking enterprises reporting CFC's losses must provide
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