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...
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 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...
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...
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...
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...
The Swedish parliament (Riksdag) has adopted a draft bill proposing a temporary reduction in tax on petrol and diesel, aimed at offsetting rising fuel prices linked to the ongoing conflict in the Middle East. The measure forms part of an additional amending budget approved by the Riksdag. The proposal also includes the introduction of temporary...
Brazil’s government has introduced legislation proposing to use windfall revenue from elevated oil prices to finance temporary cuts in federal fuel taxes, as geopolitical tensions in the Middle East drive energy costs higher. Planning Minister Bruno Moretti outlined the bill on Thursday, 23 April 2026, emphasising that the initiative is designed to maintain complete fiscal...
The German Federal Government has announced plans to modernise tax advice and reduce bureaucracy through the Ninth Act Amending the Tax Advisory Act, aimed at expanding advisory services for citizens while simplifying regulatory requirements. The reform was outlined on Friday, 24 April 2026. The draft law includes four key changes: First, the powers of wage...
New Zealand’s Inland Revenue (IR) initiated a consultation on 24 April 2026 on a proposed Approved Information Sharing Agreement (AISA) with the New Zealand Customs Service aimed at reducing Working for Families tax credit overpayments when recipients leave New Zealand and become ineligible. The proposal will enable Customs to automatically share border movement information with...