Monday, April 27, 2026
Irish Revenue published eBrief No. 063/26 on 25 March 2026, providing updated guidance on the participation exemption for specified foreign distributions Participation exemption for certain foreign distributions Tax and Duty Manual (TDM) Part 35-02-11 provides guidance on the participation exemption in section 831B TCA 1997, which is a corporation tax exemption for foreign-sourced dividends and...
The German Ministry of Finance (MOF) on 20 March 2026 published a draft bill to implement the Multilateral Competent Authority Agreement on the Exchange of Global Anti-Base Erosion (GloBE) Information Returns (GIR MCAA), which Germany signed on 19 September 2025. The law is expected to enter into force the day after promulgation. The GIR MCAA...
The Russian Ministry of Finance (MoF) published updated guidance on requesting assistance under the Mutual Agreement Procedure (MAP), setting out detailed rules for taxpayers seeking relief from double taxation under applicable double taxation agreements (DTAs) on 20 March 2026. The guidance explains that MAP is a mechanism allowing the Russian competent authority and its treaty...
The Australian Taxation Office has released guidance on tax consolidated group restructures and transition rules, outlining how Australia’s Pillar 2 minimum tax rules apply to acquisitions, restructures, and other ownership or asset transfers within tax consolidated groups. The guidance covers the following: Restructure rules and transition rules for tax consolidated groups The Pillar Two rules...
The Australian Taxation Office has opened a public consultation on Draft Practical Compliance Guideline PCG 2026/D1, covering thin capitalisation and the allocation of risk-weighted assets to Australian branches of foreign banks. This guideline: addresses a thin capitalisation issue impacting foreign banks that conduct their banking business in Australia through a branch outlines our approach to...
India’s Lok Sabha (lower house of parliament) has approved the Finance Bill 2026 with amendments on 25 March 2026. It now awaits approval by the Rajya Sabha. The bill implements the Union Budget 2026–27, including measures to introduce the new Income Tax Act 2025 from 1 April 2026. The Union Budget 2026–27 includes proposals centred...
The French tax authority has released the statement of assessment of the supplementary (top-up) tax (Form 2272-SD) and related guidance for reporting supplementary (top-up) tax. The form must be filed by parent or constituent entities subject to the Pillar 2 income inclusion rule (IIR), the undertaxed payment/profit rule (UTPR), or the qualified domestic minimum top-up...
Sweden’s parliament has approved legislation to implement Council Directive (EU) 2025/872 (DAC9) on 25 March 2026. The primary provisions and the new law are proposed to enter into force on 1 May 2026. This legislation details a proposal to implement global minimum tax standards for large multinational corporations through the DAC9 directive and the GloBE...
Finland has gazetted Law 187/2026 of 20 March 2026, introducing several amendments to the Minimum Tax Act for Large Groups, aligning national law with European Union directives on global tax standards. The changes align domestic legislation with the latest guidance issued by the OECD/G20 Inclusive Framework in 2024 and 2025, ensuring ongoing compliance with the...
Taiwan’s Ministry of Finance (MoF) has released a notice on 26 March 2026, outlining the possible tax exemption on business profits earned by foreign enterprises from providing electronic services, where such relief is available under applicable tax treaties. With the increasing frequency of cross-border online transactions, many profit-seeking enterprises purchase electronic services from foreign profit-...