Greece: Council of State rules interest on dividend-financing loans non-deductible
Greece's Council of State issued Decision No. 370/2026 on 11 September 2026, which clarified that companies cannot deduct interest paid on loans borrowed to finance dividend payments to shareholders. The Second Chamber of the council rejected an
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Canada: Supreme Court rejects Husky Energy bid to challenge dividend tax ruling
The Supreme Court of Canada has dismissed Husky Energy Inc.'s application for leave to appeal on 3 September 2026. The decision upholds a 2025 Federal Court of Appeal ruling that blocked the company from using a tax treaty loophole to reduce
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Australia: ATO updates PAYG withholding annual report guidance ahead of October deadline
The Australian Taxation Office has announced updated guidance on PAYG withholding annual reports for interest, dividend, and royalty payments made to non-residents on 11 September 2026. The move follows the creation of a new completion guide
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US: IRS, Treasury propose new foreign source Section 951A income, FDDEI deductions rules
The US Internal Revenue Service (IRS) and Treasury Department have issued a notice of proposed rulemaking titled Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income, published in
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Australia: ATO publishes final ruling on software royalties, expanded draft compliance guideline
The Australian Taxation Office published final Taxation Ruling TR 2026/2 Income tax: royalties – character of payments on 4 September 2026, establishing the ATO's position on software intermediation arrangements and when payments qualify as
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Italy: Omnibus tax decree, reshapes corporate tax, VAT, compliance rules
The Italian Revenue Agency has announced that it published Legislative Decree No. 148 of 7 August 2026 (the Omnibus Tax Decree) in the Official Gazette on 11 August 2026. This follows the Italian government's approval of a sweeping 37-article tax
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Kenya: President assents Finance Act 2026, introduces reduced CIT
Kenya's President has enacted the Finance Act 2026, bringing amendments across multiple tax statutes effective from 1 July 2026. The Presidential assent was given on 24 June 2026. The Finance Act, 2026, does not raise taxes. Instead, it
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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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US: Congress moves forward on digital asset tax framework
The US House Ways and Means Committee held a hearing on 9 June 2026 to explore new tax rules for digital assets, advancing eight bills and discussion drafts that aim to simplify compliance and establish clearer rules for activities like
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Denmark: Tax Authority denies automatic tax deferral on share exchange without proper asset valuations
Denmark’s tax agency issued a binding ruling on 4 June 2026 addressing the tax treatment of a proposed share exchange by a family-owned business group. In Tax Council Binding Answer No. SKM2026.264.SR, the authority clarified when such
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India expands tax exemptions for foreign investors in government securities
India has published the Income-Tax (Amendment) Commencement Ordinance 2026 in the Official Gazette on 5 June 2026, introducing a targeted set of tax reforms aimed at strengthening foreign participation in Indian Government securities markets. The
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Belgium gazettes programme law, introduces increased withholding tax rate
Belgium has gazetted the Programme Law of 30 May 2026 on 1 June 2026, a comprehensive legislative act designed to implement diverse fiscal and administrative reforms. This legislation introduces significant taxation adjustments, specifically
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Venezuela overhauls mining sector with sweeping new mining law
Venezuela has enacted a sweeping new mining regime with the publication of the Ley Orgánica de Minas (2026) in the Official Gazette on 16 April 2026, replacing two cornerstone laws that had governed the country’s mineral sector for
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Italy: Revenue Agency approves IRAP refund procedures for banks, financial institutions
The Italian Revenue Agency published Provision Prot. n. 123184/2026 on 22 April 2026, which outlines the formal procedures for claiming a refund or utilising compensation for the portion of Regional Tax on Productive Activities (IRAP) paid on
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Netherlands consults stricter anti-dividend stripping rules with 15% net return test
The Dutch Ministry of Finance has initiated a public consultation regarding additional measures to prevent dividend stripping on 16 April 2026. Dividend stripping is a method by which individuals or companies attempt to pay less or no tax on
See MoreItaly: Tax Court of Appeals grants US company lower tax rate on dividends in ruling
The Italian Tax Court of Appeals of Abruzzo delivered a decision on 17 February 2026 (Decision 93/2026), allowing a US corporation to benefit from a reduced 1.2% withholding tax rate on dividends received from its Italian subsidiary. Case
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Ghana cuts growth and sustainability levy after adopting variable royalty system for gold, lithium
Ghana's President have signed the Growth and Sustainability Levy (Amendment) Bill 2026 into law on 31 March 2026. Referring to the amendment to the Growth and Sustainability Levy Act, the President stated that the levy had previously been
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Poland proposes major reforms in CIT Act, targets hidden dividends and minimum tax rules
Poland has announced a law on 16 March 2026 that proposes sweeping changes to the Corporate Income Tax (CIT) Act, targeting business definitions, expense deductibility, and specialised tax regimes. These changes aim to refine definitions, introduce
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