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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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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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
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
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
See MoreFinland: MoF consults on OECD-based PE profit attribution
The deadline to submit comments is 30 June 2025. Finland’s Ministry of Finance has opened a public consultation to amend three key tax laws: the Income Tax Act, the Act on Taxation of Business Income, and the Act on the Elimination of
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Australia: ATO revises corporate tax residency guidelines
The ATO updated its corporate tax residency guidelines on 11 June 2025, clarifying the central management and control (CMC) test The Australian Taxation Office (ATO) updated its corporate tax residency guidelines in PCG 2018/9 on 11 June 2025,
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Hong Kong passes law allowing company re-domiciliation
The inward re-domiciliation regime in Hong Kong was enacted on 23 May 2025, allowing non-Hong Kong companies to re-domicile while keeping their legal identity and business continuity. The Hong Kong company inward re-domiciliation regime became
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Belarus updates tax guidance for foreign permanent establishments
The Belarus Ministry of Taxes and Duties has published Letter No. 4-2-21/01461 of 18 April 2025 on taxing foreign organisations operating in Belarus through a permanent establishment. The letter replaces Letter No. 4-2-21/00850 of 20 March 2024, and
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Switzerland: Tax Administration clarifies tax treatment of permanent establishments under Pillar two GloBE rules, Swiss minimum tax
The Swiss Federal Tax Administration published Communication-023-E-2025-f on 18 March 2025, addressing the tax treatment of constituent entities qualifying as permanent establishments under the GloBE rules and the Swiss Minimum Tax Ordinance. The
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China revises tax residency certificate rules
China's State Administration of Taxation has released Announcement No. 4 of 2025 outlining revised rules and procedures for obtaining a "Certificate of Tax Residency" for enterprises and individuals. The Announcement No. 4 of 2025 will take
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Italy clarifies permanent establishment exemption for investment management
Italy’s tax authorities released Circular No. 23/E on 19 November 2024, outlining the guidelines for the permanent establishment investment management exemption introduced in the 2023 Budget Law. One of the key provisions in the 2024 Budget Law
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