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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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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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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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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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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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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Belgium clarifies financial fixed asset requirement for dividend withholding tax exemption
Following parliamentary questions, the Belgian Minister of Finance has provided clarification on the financial fixed asset condition for applying the Tate & Lyle dividend withholding tax exemption (the exemption) for dividends paid to
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Cyprus: Tax Department announces new payment method for defence, health contributions
The Cyprus Tax Department announced, on 26 March 2026, the introduction of a temporary change in how certain contributions are paid for the 2026 tax year. For the time being, taxpayers will make payments for the following contributions directly
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Taiwan: Foreign dividends from China-listed companies now taxable for domestic enterprises
Taiwan's Ministry of Finance has issued a notice on 26 March 2026 that when a profit-seeking enterprise with its head office located within the territory of China invests in shares issued by a foreign company that has been approved to list and trade
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France issues guidance on treaty-based dividend withholding relief
France’s tax authority has issued guidance clarifying its taxation methods for dividends and similar income under international tax treaties, particularly focusing on treaty benefits for distributions to residents of countries with specific
See MoreTaiwan: MoF explains withholding tax on non-resident dividends
Taiwan’s National Taxation Bureau of the Northern Area (NTBNA) under the Ministry of Finance, issued a notice on 10 March 2026 indicating that, where dividends are distributed by a company to an individual not residing in China or profit-seeking
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Philippines: Tax court upholds dividend withholding tax exemption for foreign government investors
The Philippine Court of Tax Appeals ruled on 26 February 2026 concerning the withholding tax exemption on dividends under Section 32(B)(7)(a) of the National Internal Revenue Code (NIRC) of 1997. Section 32(B) excludes certain income items from
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Ireland: Share scheme returns for 2025 due in March 2026
Irish Revenue has issued eBrief No. 039/26 on 27 February 2026, reminding customers that the deadline for the share reporting obligation in respect of the return year 2025 is 31 March 2026. Failure to make a return by the due date may attract
See MoreBelgium: MoF introduces 5% capital gains tax for shareholding investment firms
Belgium's Ministry of Finance issued Circular 2026/C/33 on 24 February 2026, establishing a separate 5% capital gains tax on the disposal of shares in SICAV-RDT/DBI-BEVEK investment companies effective from the assessment year 2026. It also
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