US: IRS issues guidance on elections for business interest limitation relief, bonus depreciation exemption
The US Internal Revenue Service (IRS) issued Revenue Procedure 2026-17, which provides guidance on withdrawing elections for excepted trades or businesses under §163(j)(7) and making late elections to opt out of bonus depreciation under
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Kazakhstan approves country list for CFC exemption tied to corporate tax thresholds, treaty criteria
Kazakhstan's Minister of Finance has approved a comprehensive list of countries whose businesses qualify for double taxation treaty benefits based on their corporate tax rates. The approved countries must maintain a nominal corporate income tax
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Korea (Rep.) introduces transfer pricing reforms, Pillar Two rollout
Korea (Rep.) has published Presidential Decree No. 36128, partially amending the enforcement Decree of the International Tax Adjustment Act, in the Official Gazette on 27 February 2026. The Decree introduces sweeping updates to its international tax
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Taiwan: Northern Tax Bureau issues reminder on CFC rules
Taiwan’s Northern District National Taxation Bureau has issued a reminder to businesses regarding the Controlled Foreign Company (CFC) rules, which came into effect in 2023. The rules were introduced to prevent multinational enterprises from
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Italy clarifies Swiss cantonal net wealth tax not creditable against CFC tax
The Italian tax authorities have issued Ruling Answer No. 70/2026, which addresses a specific tax query regarding whether a Swiss cantonal tax—the "Capital Tax"—can be deducted from the Italian taxes due under the Controlled Foreign Company
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Russia reminds organisations to file 2025 CFC notifications
Russia has reminded organisations that the deadline to submit notifications on controlled foreign companies (CFCs) for 2025 expires on 20 March 2026. This announcement was made on 4 March 2026. A CFC notification must be filed regardless of
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CJEU rules Belgium non-compliant for excluding foreign tax credits under ADAT CFC framework
The Court of Justice of the European Union (CJEU) delivered a judgment on 26 February 2026, examining how Belgium has transposed the Controlled Foreign Company (CFC) rules under the Anti-Tax Avoidance Directive (ATAD). The case centred on whether
See MoreTaiwan highlights common errors in corporate income tax filings
The Northern District National Taxation Bureau of the Ministry of Finance issued guidance yesterday, 24 February 2026, ahead of the filing period for the 2025 Profit-Seeking Enterprise Income Tax Return and the 2024 Undistributed Earnings Return,
See MoreTaiwan clarifies CFC rules on low-tax jurisdiction gains, losses
Taiwan’s Northern National Taxation Bureau of the Ministry of Finance has reminded profit-seeking enterprises that when calculating Controlled Foreign Corporation (CFC) annual earnings, investment gains or losses originating from “low-tax
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Russia updates VAT, corporate tax rules
Russia has enacted a series of tax reforms for 2026 under Federal Law No. 425-FZ of 28 November 2025, introducing changes across VAT, corporate taxation, and digital asset regulation. The reforms took effect on 1 January 2026. The standard VAT
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Germany: Bundesrat approves Pillar 2 tax amendments, DAC 9 information exchange
Germany ’s Federal Council (Bundesrat) approved a bill (Gesetz zur Anpassung des Mindeststeuergesetzes und zur Umsetzung weiterer Maßnahmen) on 19 December 2025 amending the country’s Pillar 2 minimum taxation framework. The bill updates the
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Taiwan clarifies CFC financial statement deadline applications
The Northern Taiwan National Taxation Bureau of the Ministry of Finance stated that, in line with international anti-tax avoidance trends and to maintain tax fairness, Taiwan’s Controlled Foreign Corporation (CFC) regime has been implemented
See MoreTaiwan: Tax Bureau clarifies CFC investment income deductions
Taiwan’s National Taxation Bureau, under the Ministry of Finance, has clarified rules on the calculation of Controlled Foreign Company (CFC) investment income for profit-seeking enterprises, emphasising that accumulated losses recorded in a
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Austria: MOF consults 2025 tax reform, proposes updates to Pillar 2 rules
Draft bill introduces income tax inflation adjustments and updates to global minimum tax rules, with consultation open until 3 November 2025. The Austrian Ministry of Finance (MOF) has released the draft Tax Amendment Act 2025
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Japan updates guidance on global minimum tax
NTA updated its guidance on global minimum tax rules, clarifying calculations and key definitions. Japan's National Tax Agency (NTA) released a revised version of its interpretative guidance on global minimum tax rules on 26 September
See MoreKazakhstan: MoF approves new CFC reporting, taxation forms for 2026
Ministry of Finance introduced new forms for reporting and taxing Controlled Foreign Companies, effective 1 January 2026. Kazakhstan’s Ministry of Finance issued Order No. 536 on 25 September 2025, approving new forms for the reporting and
See MoreKazakhstan: MOF updates CFC preferential tax jurisdictions list
Kazakhstan approved a 56-country CFC preferential tax list, effective from 1 January 2026. Kazakhstan’s Ministry of Finance (MOF) approved Order No. 492 of 12 September 2025, updating the list of countries and territories with preferential
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Ukraine: STS clarifies CFC reporting penalties
Ukraine requires annual CFC reports, with penalties waived during martial law if filed within six months after it ends. Ukraine’s State Tax Service (STS) has clarified that, under the country’s controlled foreign company (CFC) rules, a
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