Posts by: RF Report


Netherlands limits split-up tax deferrals, explicitly excludes anti-abuse protections

The Netherlands has published Decree No. 2026-262957 of 6 August 2026 (demergers) from the State Secretary for Finance on pure demergers on 18 August 2026. The Decree No. 2026-262957 of 6 August 2026 outlines the Dutch tax policy regarding pure split-ups (corporate divisions) under the Corporate Income Tax Act 1969. This decree details the updated...

Brazil advances tax compliance plan for IBS, CBS transition

Brazil’s Federal Revenue, the Management Committee of the Goods and Services Tax (CGIBS) and the Federal Accounting Council (CFC) have agreed on measures to implement the National Tax Compliance Plan (PNCT), including requirements for tax documents and the role of accounting professionals during the transition to the new consumption tax system. The agreement was discussed...

Taiwan reminds businesses of 2026 provisional corporate tax filing rules

Taiwan’s Kaohsiung National Taxation Bureau, Ministry of Finance, has reminded businesses that the 2026 provisional corporate income tax filing period will begin on 1 September 2026. Businesses using the “standard provisional payment” method do not need to include the separately calculated Land and Buildings Consolidated Tax from the previous year when calculating their provisional tax...

Germany: Federal Fiscal Court clarifies minimum taxation, loss carryforwards

Germany’s Federal Fiscal Court (BFH) has confirmed the constitutionality of statutory minimum taxation rules while finding that tax authorities must reconsider a request for equitable relief where restrictions on loss carryforwards create a permanent tax burden that was not intended by the legislature. The First Senate issued its judgment on 15 April 2026, in case...

Germany gazettes amended minimum tax report ordinance

Germany has amended and renamed its Minimum Tax Report Ordinance, restructuring the regulation and adding a comprehensive list of foreign tax jurisdictions recognised for the purposes of the country’s Minimum Tax Act, according to a notice published in the Federal Law Gazette (Bundesgesetzblatt) Part I, No. 235 issued on 17 August 2026. The Ordinance Amending...

China grants corporate tax deferral on equipment swaps for chipmakers, machine tool firms through 2028

China’s Ministry of Finance, State Taxation Administration, National Development and Reform Commission, and Ministry of Industry and Information Technology issued Announcement No. 23 of 2026 on 31 July 2026, establishing a temporary corporate income tax relief for non-monetary asset exchanges by integrated circuit enterprises and industrial machine tool enterprises. Five-year deferral on exchange income The...

US: Treasury, IRS consults CFC election to simplify Section 987 foreign currency rules

The US Department of the Treasury and the IRS have initiated a public consultation regarding proposed regulations (REG-103844-26) allowing controlled foreign corporations (CFCs) to elect not to compute or recognise foreign currency gain or loss under Internal Revenue Code (IRC) section 987 upon a remittance from a qualified business unit (QBU), except in certain inbound...

Brazil announces deadline to apply for the Simplified National Tax Regime

Brazil’s Federal Revenue Service (RFB) announced, on 19 August 2026, that companies wishing to join the Simplified National Tax Regime (Simples Nacional) must submit applications in September 2026 rather than January 2027. The change stems from CGSN Resolution No. 186, published in the Official Gazette on 17 April 2026, which reorganises the regime’s implementation in...

Slovak Republic: Government approves draft bill to implement Side-by-Side package

The Slovak Republic government has approved a draft bill amending Act No. 507/2023 Coll., which implements the EU Minimum Taxation Directive. The draft bill was approved by Government Resolution No. 320/2026 on 19 August 2026. The bill introduces further adjustments arising from the OECD/G20 Inclusive Framework’s Side-by-Side Package, adopted on 5 January 2026, including related...

US delays 50% additional tariffs on certain Canadian goods

The US has delayed the imposition of 50% additional tariffs on certain Canadian goods by three days as the two countries continue negotiations over longstanding trade disputes. The tariffs, originally scheduled to take effect on 19 August 2026, will instead enter into force at 12:01 AM ET on 22 August 2026, under the Presidential Proclamation...