Posts by: RF Report


Philippines: BIR clarifies tax treatment of cross-border services

The Bureau of Internal Revenue (BIR) of the Philippines issued Revenue Memorandum Circular (RMC) No. 24-2026 on 30 March 2026  to clarify the application of RMC Nos. 5-2024 and 38-2024 on the taxation of cross-border services. The circular aligns previous issuances with the Supreme Court ruling in the Aces Philippines case and provides guidance on...

Hungary maintains 0% advertising tax rate despite earlier reinstatement plans

Hungary has gazetted Government Decree No. 87/2026 on 23 April 2026, which maintains the 0% advertising tax rate in effect since 1 July 2019. Without this intervention, the advertising tax would have been reinstated on 1 July 2026. The new decree ensures the rate remains at 0% of the tax base starting from that date....

Canada signals US trade talks may continue past CUSMA review deadline 

Canada’s chief trade negotiator, Janice Charette, has indicated on Tuesday, 21 April 2026, that not all trade disputes with the US will be settled by the 1 July review deadline for the North American free trade agreement, but emphasised this won’t trigger the deal’s collapse. Speaking at a Canadian Chamber of Commerce event in Ottawa,...

Kenya: KRA to integrate export process in iCMS with the VAT return in iTAX

Kenya’s tax authority (KRA), in a release on 23 April 2026, has notified taxpayers and the public that, effective May 2026, the VAT  return export data in ICMS will be integrated with the declaration of zero-rated supplies in the VAT return in iTax. This means that validated export values will be automatically prefilled in the...

Montenegro proposes draft corporate tax rules in accordance to EU ATAD

The Government of Montenegro has released a draft law on Amendments to the Law on Corporate Income Tax, proposing measures to address profit shifting in accordance with the EU Anti-Tax Avoidance Directive (ATAD) (Directive 2016/1164 as amended by Directive 2017/952). Key anti-profit shifting rules Interest limitation rule: A taxpayer’s deductible borrowing costs are limited to...

UK: HMRC proposes CCA scheme expansion, carbon factor update from 2027

The UK’s HMRC has issued a policy paper on 20 April 2026, outlining proposed updates to the Climate Change Agreements (CCA) scheme in the UK. The proposal focuses on expanding eligibility to additional energy-intensive activities, refining key calculation methods linked to emissions performance, and consolidating existing regulations. Together, the proposals are intended to strengthen the...

Hong Kong strengthens tax treaty network to enhance regional competitiveness, including incentives for corporate treasury centres

Hong Kong is accelerating efforts to expand its tax agreement framework following the signing of its 57th Comprehensive Avoidance of Double Taxation Agreement with Barbados in March 2026. Financial Services and Treasury Secretary Christopher Hui revealed the expansion strategy in a press release on 22 April 2026, while addressing comparisons with Singapore, which currently maintains...

Chile: SII updates rules on dividend tax credits for Chinese shareholders

The Chilean tax authority (SII) issued Letter Ruling No. 794 on 15 April 2026, addressing how Chilean companies should handle dividend withholding taxes when distributing profits to Chinese resident shareholders, particularly when the company has insufficient tax credit balances. Treaty framework and tax rates Under Chilean domestic law, dividends paid to foreign shareholders normally face...

Singapore: IRAS updates tax framework for Variable Capital Companies in fourth edition guide

The Inland Revenue Authority of Singapore (IRAS) issued an updated e-Tax Guide, Tax Framework for Variable Capital Companies (Fourth Edition) on 22 April 2026. This e-Tax Guide sets out the tax framework for Variable Capital Companies (VCCs), a specialised corporate structure designed for investment funds. For income tax purposes, a VCC is generally treated as...

US: Taxpayer Advocacy Panel issues 2025 annual report highlighting taxpayer-focused recommendations to improve tax administration

The US IRS has announced that the Taxpayer Advocacy Panel has released its 2025 Annual Report on 24 April 2026, highlighting accomplishments and ongoing efforts to strengthen Internal Revenue Service delivery, improve communications with taxpayers, reduce taxpayer burden, and support continued modernization of tax administration. “In 2025, TAP members dedicated hundreds of volunteer hours to...