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,
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Italy 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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Australia: ATO issues guidance on revising global, domestic minimum tax assessments, GIR
The Australian Taxation Office (ATO) issued new guidance on Amending a global and domestic minimum tax assessment and Globe Information Return (GIR) on 31 March 2026. Check if an amendment is needed To correct mistakes in relation to the
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Greece consults DAC9 Top-up Tax Information Return, DAC8 crypto-asset reporting
The Greek Ministry of Finance (MoF) has launched a public consultation on a draft bill aimed at modernising administrative cooperation in taxation and implementing recent European Union directives on 29 March 2026, after which it is expected to
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Netherlands introduces ‘Freedom Contribution’ in 2026 Spring Memorandum
The Dutch Government has published the Spring Memorandum 2026, updating the 2026 budget and outlining forward-looking plans, including a range of tax measures. Key provisions reflect those agreed in the Coalition Agreement for 2026–2030, released
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Greece confirms UTPR, transitional CbCR safe harbours under Pillar Two enters into force
Greece’s Ministry of Finance (MoF) has confirmed that the undertaxed profits rule (UTPR) and the transitional country-by-country reporting (CbCR) safe harbours under Pillar Two, as established in the Minimum Taxation Directive (2022/2523),
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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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Germany: MoF publishes draft bill to implement GloBE information exchange
The German Ministry of Finance (MOF) on 20 March 2026 published a draft bill to implement the Multilateral Competent Authority Agreement on the Exchange of Global Anti-Base Erosion (GloBE) Information Returns (GIR MCAA), which Germany signed on 19
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Australia: ATO issues guidance on Pillar Two rules for tax consolidated group restructures, transition rules
The Australian Taxation Office has released guidance on tax consolidated group restructures and transition rules, outlining how Australia’s Pillar 2 minimum tax rules apply to acquisitions, restructures, and other ownership or asset transfers
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Australia: ​​ATO consults on thin capitalisation compliance, risk-weighted asset allocation for foreign bank branches
The Australian Taxation Office has opened a public consultation on Draft Practical Compliance Guideline PCG 2026/D1, covering thin capitalisation and the allocation of risk-weighted assets to Australian branches of foreign banks. This
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France releases form for statement of assessment of the supplementary (top-up) tax
The French tax authority has released the statement of assessment of the supplementary (top-up) tax (Form 2272-SD) and related guidance for reporting supplementary (top-up) tax. The form must be filed by parent or constituent entities subject to the
See MoreSweden: Parliament approves law to implement DAC9, GIR MCAA
Sweden’s parliament has approved legislation to implement Council Directive (EU) 2025/872 (DAC9) on 25 March 2026. The primary provisions and the new law are proposed to enter into force on 1 May 2026. This legislation details a proposal to
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Finland updates minimum tax act to reflect latest Pillar Two guidance, implements Side-by-Side package
Finland has gazetted Law 187/2026 of 20 March 2026, introducing several amendments to the Minimum Tax Act for Large Groups, aligning national law with European Union directives on global tax standards. The changes align domestic legislation with
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UN Tax Committee Discusses Guidance on AI for Tax Administrations
On 25 March 2026 the UN Committee of Experts on International Cooperation in Tax Matters discussed the proposed workstream for the guidance on tax administration and AI. The subcommittee presented its planned work for comment and approval. The
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UN Tax Committee Discusses Manual on the Negotiation of Bilateral Tax Treaties
On 24 March 2026 the UN Committee of Experts on International Cooperation in Tax Matters discussed the workplan for updating the Manual on the Negotiation of Bilateral Tax Treaties. The relevant subcommittee presented its planned workstreams for
See MoreAustralia consults Board of Taxation’s review of thin capitalisation amendments
The Australian Board of Taxation released a consultation guide marking the beginning of a formal statutory review of recent reforms to the nation's thin capitalisation rules in March 2026. This consultation guide outlines an independent statutory
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