Philippines: BIR begins preparations for implementation of Pillar Two QDMTT
The Philippines Bureau of Internal Revenue (BIR) announced on 11 June 2026, through a Facebook post, that it has begun preparations for the possible implementation of the proposed Qualified Domestic Minimum Top-Up Tax (QDMTT), a measure pushed by
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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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CJEU Advocate General supports Luxembourg’s ATAD transposition on securitisation entities from interest limitation rules
The Advocate General (AG) Juliane Kokott of the Court of Justice of the European Union (CJEU) has issued her opinion in Case C-138/24, involving an infringement claim by the European Commission against the Grand Duchy of Luxembourg on 18 June
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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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Malaysia gazettes employer tax incentive for flexible work practices
Malaysia has gazetted the Income Tax (Deduction for the Costs of Implementation of Flexible Work Arrangements) Rules 2026 on 16 June 2026. The Income Tax (Deduction for the Costs of Implementation of Flexible Work Arrangements) Rules 2026
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Canada: Spring Economic Update 2026 receives Royal Assent
Canada’s Department of Finance announced that Bill C‑30, An Act to implement certain provisions of the Spring Economic Update tabled in Parliament on 28 April 2026, has received Royal Assent on 19 June 2026. It delivers targeted measures to
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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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Brazil: RFB refines CSLL additional tax framework under GloBE rules
Brazil’s Federal Revenue Service (RFB) has published the Normative Instruction RFB No. 2,329 on 19 June 2026, amending the rules governing the Additional Social Contribution on Net Profit (CSLL) surcharge as per Normative Instruction RFB No. 2,228
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Australia: ATO issues guidance on GIR XML file requirements for globe information return
The Australian Taxation Office (ATO) has recently issued guidance on the XML file requirements for the GloBE Information Return (GIR), offering clarification to assist filers in completing specific GIR data elements. When preparing the GloBE
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Italy: Supreme Court rules treaty rights override domestic filing requirements in double taxation cases
Italy’s Supreme Court, in Ordinance No. 16134 of 25 May 2026, held that relief from double taxation under the Italy–Germany income and capital tax treaty cannot be refused solely because the taxpayer failed to file an Italian tax return or
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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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South Africa issues guidance on global minimum tax filing requirements for MNEs
The South African Revenue Service (SARS) has published guidance outlining how in-scope multinational enterprises (MNEs) must submit the global minimum tax return (GMT01), the global minimum tax declaration form (GMT02), and the related tax
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Belgium consults draft undertaxed payments rule (UTPR) top-up tax return for 2025
Belgium has launched a public consultation on a draft undertaxed payments rule (UTPR) top-up tax form and related explanatory guidance for the 2025 tax year. UTPR explanatory guidance Issued by the Federal Public Service Finance, the official
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Netherlands: Exit payments from departing cooperative members are taxable profit
The Netherlands Tax Administration’s Knowledge Group, responsible for specific corporate tax profit determination, has issued a position outlining the corporate income tax treatment of exit payments received by a cooperative from members who
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Belgium gazettes decree on QDMTT, IIR return forms for 2025 assessment year
Belgium’s Ministry of Finance has gazetted Royal Decrees establishing the return forms for both the Qualified Domestic Minimum Top-Up Tax (QDMTT) and the Income Inclusion Rule (IIR) for the 2025 assessment year. Both Royal Decrees of 5 June 2026
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Austria: Draft Budget Accompanying Act 2027–2028 sets out progressive CIT rate
Austria’s government has submitted the Draft Budget Accompanying Act 2027–2028 to Parliament, introducing a range of tax measures under the dual budget framework for 2027 and 2028. The proposals aim to strengthen fiscal consolidation efforts,
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Portugal further extends CIT deadline for Form 22 filing, payment
Portugal has granted a further extension for the submission of the periodic corporate income tax return (Form 22) and the corresponding payment for the 2025 tax period, moving the deadline from 19 June to 30 June 2026. The extension was announced
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