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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Taiwan: Businesses reminded to apply for CFC financial statement filing extensions
The Kaohsiung National Taxation Bureau of the Ministry of Finance announced on 25 May 2026 that, for any reason, those who are unable to submit their CFC financial statements within the prescribed period may apply to their local tax authority for an
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Taiwan: Tax bureau reminds firms of CFC financial statement filing deadline
Taiwan’s Northern Taiwan National Taxation Bureau of the Ministry of Finance announced that the filing period for the 2025 profit-seeking enterprise income tax return is from May 1 to May 31, 2026 (extended to June 1 if the deadline falls on a
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Taiwan clarifies CFC document extension rules for corporate tax filings
Taiwan’s Central District National Taxation Bureau of the Ministry of Finance clarified that profit-seeking enterprises required to report income from Controlled Foreign Corporations (CFCs) must disclose relevant information and attach supporting
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Canada tables bill introducing budget measures, includes amendments to Global Minimum Tax Act
Canada's Department of Finance has tabled the Notice of Ways and Means Motion to introduce a bill entitled A second Act to implement certain provisions of the budget in Parliament on 4 November 2025. The bill introduces a range of measures,
See MoreTaiwan tightens 2023 CFC audits, flags misreported income breaching de minimis threshold
Taiwan’s National Taxation Bureau of the Northern Area, MOF, stated, on 30 April 2026, that it has strengthened audits of Controlled Foreign Corporation (CFC) cases for the year 2023 on profit-seeking enterprise income tax filings within its
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Montenegro proposes draft corporate tax rules in accordance to EU ATAD
The Government of Montenegro has released a draft law on Amendments to the Law on Corporate Income Tax, proposing measures to address profit shifting in accordance with the EU Anti-Tax Avoidance Directive (ATAD) (Directive 2016/1164 as amended by
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Italy: Revenue Agency updates tax codes for transition 5.0 credit, CFC regime
The Italian Revenue Agency has introduced new tax codes to facilitate payments under two distinct fiscal frameworks: the Transition 5.0 plan and the reformed controlled foreign companies (CFC) regime. These updates aim to streamline tax compliance
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Russia urges individuals to submit CFC notifications before April deadline
The Russian Federal Tax Service has issued a reminder that individuals are required to submit the annual notification on controlled foreign companies (CFCs) for the 2025 tax year by 30 April 2026. This obligation applies regardless of the financial
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Japan enacts 2026 tax reform, implements side-by-side safe harbour
Japan’s National Diet approved the 2026 tax reform legislation on 31 March 2026, which has been published in the Official Gazette. The measures reflect proposals released in December 2025 and January 2026, covering income, corporate,
See MoreItaly issues rules for optional substitute tax as alternative to CFC regime
Italy’s tax authorities have issued updated guidance, under Protocol No. 106520 of 31 March 2026, which details the voluntary tax option that allows Italian controlling entities to pay a flat 15% substitute tax on the net accounting profits of
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Sweden implements Side-by-Side, UPE safe harbours under global minimum tax
Sweden's Ministry of Finance (MoF) has proposed amendments to the Additional Tax Act (2023:875) to implement the side-by-side arrangement agreed by the OECD Inclusive Framework on 5 January 2026. The changes aim to align Swedish law with OECD/G20
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Czech Republic updates non-cooperative jurisdictions list for CFC rules, adds Vietnam
The Czech Republic has published Financial Bulletin No. 5/2026 on 20 March 2026, which includes an updated list of jurisdictions classified as non-cooperative for tax purposes, aligning its domestic rules with the latest decisions of the Council of
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