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
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UK: HMRC publishes Oil and Gas Revenue Levy, foreign PE reforms for Finance Bill 2026-27
The UK HMRC has published policy papers, draft legislation, and explanatory notes covering two proposed tax measures: the introduction of a new Oil and Gas Revenue Levy to replace the existing Energy Profits Levy, and reforms to the foreign
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Australia: ATO updates guidance on taxation of permanent establishments
The Australian Taxation Office (ATO) updated its guidance on the taxation of permanent establishments (PEs) on 24 June 2026, outlining when enterprises may be subject to tax in Australia or overseas under Australia's double tax agreements
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Finland establishes permanent tax residency framework for foreign investment funds
The President of Finland ratified a law that brings amendments to the Income Tax Act concerning the tax residency rules for certain foreign investment funds on 16 June 2026. Under Finland’s general rules, a foreign entity can be treated as a
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Poland gazettes notice identifying 44 jurisdictions with QIIR, 49 with QDMTT under GloBE rules
Poland has issued a notice identifying jurisdictions, other than Poland, that have introduced a qualified income inclusion rule (QIIR) or a qualified domestic minimum top-up tax (QDMTT), or that satisfy the QDMTT safe harbour conditions. The notice,
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Germany updates guidance on permanent establishments under domestic, international tax law
Germany’s Ministry of Finance has published updated administrative principles on the concept and establishment of permanent establishments (PEs) under domestic and international tax law, providing detailed guidance for both resident and
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Taiwan highlights key changes under renewed Singapore tax agreement
Taiwan’s National Taxation Bureau of the Central Area, Ministry of Finance ( NTBCA) stated, on 5 June 2026, that the renewed “Agreement between the Taipei Representative Office in Singapore and the Singapore Trade Office in Taipei for the
See MoreGermany clarifies permanent establishment rules in updated tax guidance
Germany's Federal Ministry of Finance has issued updated guidance on the determination of a Permanent Establishment (PE), setting out the administrative principles for assessing when a business presence constitutes a PE under domestic tax law and
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Norway consults on updates to non-cooperative tax jurisdiction lists following EU changes
Norway's Ministry of Finance opened a public consultation on 3 June 2026 regarding amendments to Regulations No. 1379 (1 July 2025) on non-cooperative jurisdictions for tax purposes. The consultation period closes on 17 June 2026, providing
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UK: Foreign PE tax exemption to become mandatory from 2027 to block overseas loss relief against profits
The UK government has announced, on 21 May 2026, changes to the taxation of UK-resident companies who conduct part of their business through foreign permanent establishments (PEs). For most companies, it will be mandatory for profits and losses
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Finland introduces comprehensive new rules for taxing permanent establishments
Finland has enacted three major tax laws—323/2026, 324/2026, and 325/2026—published in the Official Gazette on 28 April 2026, fundamentally reforming how permanent establishments operating in the country are taxed. The reforms bring Finnish
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Brazil rules US LLCs owned by Brazilian residents are privileged tax regimes
Brazil’s tax authority, the Federal Revenue Service (RFB) has determined that US Limited Liability Companies owned by Brazilian tax residents qualify as privileged tax regimes, triggering automatic annual taxation requirements. The decision came
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Cyprus tax authority publishes low-tax jurisdiction list for defensive tax measures
Cyprus Tax Department issued Circular 1/2026 on 9 April 2026, which formally establishes the list of jurisdictions classified as low-tax jurisdictions for the 2026 tax year. This circular is a critical component of Cyprus's implementation of
See MoreCyprus mandates new documentation requirements for cross-border payments to low-tax jurisdictions
Cyprus' Council of Ministers introduced three decrees (K.D.P. 131/2026, 132/2026, and 133/2026) to combat tax abuse involving payments to low-tax and non-cooperative jurisdictions on 13 March 2026. These measures, effective from 1 January 2026,
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Poland publishes tax non-cooperative jurisdictions present in EU list, absent from own
Poland’s Ministry of Finance and Economy issued an official notice on 10 March 2026 regarding countries and territories identified by the European Union as tax non-cooperative jurisdictions that are not included in Poland's domestic harmful tax
See MoreNetherlands issues tax guidance on permanent establishment requirements under Minimum Tax Act
The Dutch tax authorities issued guidance clarifying when a permanent establishment (PE) qualifies under the Minimum Tax Act 2024 (WMB 2024) on 26 February 2026, addressing critical questions about the Netherlands' implementation of the global
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Indonesia: DJP establishes specific criteria for identifying domestic, foreign tax subjects
Indonesia's Directorate General of Taxation (DJP) issued Regulation PER-23/PJ/2025, which was enacted on 9 December 2025, establishing the specific criteria for identifying domestic and foreign tax subjects. It defines domestic subjects as
See MoreGermany publishes draft permanent establishment guidelines
The German Federal Ministry of Finance has released a draft of its revised guidelines on permanent establishments (PEs) in domestic and international tax law. These guidelines are intended to replace the previous version issued in December
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