Posts by: RF Report


Korea (Rep.) issues guidance on global minimum tax filing rules for MNE groups

Korea (Rep.)’s National Tax Service (NTS) issued a release on 28 April 2026 setting out Global Minimum Tax filing requirements, including reporting obligations, filing procedures and deadlines for multinational enterprise (MNE) groups. The global minimum tax is part of the international tax reform aimed at ensuring MNE groups pay an effective minimum tax rate of...

Australia opens Pillar Two lodgments ahead of June deadline

Australia has opened lodgments for Pillar Two returns, allowing multinational enterprise (MNE) groups to begin filing ahead of the first deadline on 30 June 2026. This announcement was made on 5 May 2026. Taxpayers can now submit both the GloBE Information Return (GIR) and the combined global and domestic minimum tax return (CGDMTR) through official...

Canada tables bill introducing budget measures, includes amendments to Global Minimum Tax Act

Canada’s Department of Finance has tabled the Notice of Ways and Means Motion to introduce a bill entitled A second Act to implement certain provisions of the budget in Parliament on 4 November 2025. The bill introduces a range of measures, including significant amendments to the Global Minimum Tax Act. Additionally, this comprehensive bill introduces...

Taiwan signs customs cooperation agreement with Eswatini

Taiwan’s Ministry of Finance (MOF) announced that it signed an agreement on mutual administrative assistance in customs matters (CMAA) with Eswatini on 2 May 2026. The MOF noted that the agreement builds on the Economic Cooperation Agreement (ECA) signed between the two countries in 2018, under which both sides agreed to strengthen cooperation in customs...

Qatar signs amending protocol to income, capital tax treaty with Austria

The Qatar General Tax Authority has announced the signing of an amending protocol to the 2010 income and capital tax treaty with Austria on 3 May 2026. Key revisions include the redrafting of Article 8 on international maritime and air transport, the revision of Article 10 on dividends to clarify the scope of eligible government...

San Marino ratifies amending protocol to tax treaty with Georgia

San Marino has ratified an amending protocol that updates its income and capital tax treaty with Georgia, according to Council Decree No. 63 published on 30 April 2026. The protocol, which was signed on 17 October 2025, introduces a significant change to Article 25 covering the Mutual Agreement Procedure. The amendment removes the previous time...

Malta, San Marino: Amending protocol to tax treaty enters into force

The amending protocol to the 2005 income tax treaty between Malta and San Marino entered into force on 22 April 2026. Signed on 1 April 2024, the protocol removes the three-year time limit for resolving cases under the Mutual Agreement Procedure. It goes into effect from the date of its entry into force, 22 April...

Tanzania, Turkey sign income tax treaty

Tanzania’s Ministry of Finance has announced that it has signed an income tax treaty with Turkey on 4 May 2026. This follows after the second round of negotiations regarding the conclusion of a double taxation avoidance agreement between Turkey and Tanzania, which was held in Dar es Salaam from 17 – 20 February, 2025. The...

Croatia: Parliament approves tax treaty with New Zealand

Croatia’s parliament has passed the law for the ratification of the income tax treaty with New Zealand on 30 April 2026. The agreement, which was signed on 20 November 2025, establishes comprehensive tax rules between the two nations. The agreement aims to eliminate double taxation and prevent tax evasion between the two countries. The treaty...

South Africa: Constitutional Court dismisses ABSA appeal, upholds tax avoidance recharacterisation

The Constitutional Court of South Africa has dismissed the appeal in Absa Bank Ltd and Another v CSARS (CCT 72/24), a case concerning a ZAR 1.9 billion structured investment scheme, in a judgment delivered on 22 April 2026. The dispute involved ABSA Bank Limited and its subsidiary United Towers (Pty) Limited, which invested between 2011...