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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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
See MoreItaly 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
See MoreRussia 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
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