Posts by: RF Report


New Zealand consults tax framework for off-market share cancellations

New Zealand’s Inland Revenue has released a draft Operational Statement for public consultation addressing the bright line tests used to classify off-market share cancellations as either taxable dividends or non-taxable capital returns. This operational statement provides guidance on the tax treatment of off-market share cancellations, focusing on the bright line tests and the Commissioner’s notice...

Netherlands consults proposed reforms to expat taxation, cross-border director tax relief

The Netherlands initiated a public consultation on draft legislation to amend expat taxation, share acquisition price rules after emigration, and unilateral double taxation relief for directors and supervisory board members. The consultation runs from 13 February 2026 to 13 March 2026. The key points of the draft legislation are as follows: Taxation of expats The...

Bosnia and Herzegovina updates individual income tax rules

The Federation of Bosnia and Herzegovina has published amendments to its Rulebook on the Implementation of the Income Tax Law. The changes appear in Official Gazette No. 12/26  on 13 February 2026. The update adds a new provision to Article 10, paragraph (1), introducing item h), which covers: Regulations on the payment of assistance to...

Turkey extends Q4 2025 advance tax deadlines in areas impacted by earthquakes

The Turkish Revenue Administration has extended the filing and payment deadlines for fourth-quarter 2025 income and corporate provisional tax returns, as announced in Circular VUK-197/2026-3 on 16 February 2026. The new deadline for affected taxpayers is 9 March 2026. This extension applies to taxpayers in Adıyaman, Hatay, Kahramanmaraş, and Malatya, as well as the İslahiye...

Germany publishes draft permanent establishment guidelines

The German Federal Ministry of Finance has released a draft of its revised guidelines on permanent establishments (PEs) in domestic and international tax law. These guidelines are intended to replace the previous version issued in December 1999. The draft sets out the factual and legal requirements for creating a PE under section 12 of the...

UAE: MoF introduces unified legal framework for tax information exchange on request

The UAE Ministry of Finance issued Cabinet Decision No. 209 of 2025 on Exchange of Information upon Request for Tax Purposes on 10 February 2026. The decision establishes a unified legislative framework for the consistent application of the Exchange of Information on Request (EOIR) Standard. The Ministry stressed that since joining the OECD Global Forum...

South Africa: SARS outlines qualifying requirements for Domestic Constituent Entity GloBE Information Return

The South African Revenue Service (SARS) released the Business Requirement Specification (BRS) for the Global Anti-Base Erosion (GloBE) programme on its Global Minimum Tax webpage on 13 February 2026. This Business Requirement Specification outlines the obligations of South African domestic constituent entities to file a GloBE Information Return with SARS. It sets out the technical...

Canada joins multilateral agreement on GloBE information exchange (GIR MCAA) 

The OECD has reported that Canada signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) on 6 February 2025. The agreement is designed to enable the automatic exchange of GloBE Information Returns between tax authorities and to reduce compliance costs for multinational enterprise (MNE) groups by allowing them to submit...

EU: Turks and Caicos Islands and Vietnam non-cooperative, delists Fiji, Samoa, and Trinidad and Tobago

The EU Economic and Financial Affairs Council revised its list of non-cooperative tax jurisdictions on 10 October 2025, adding the Turks and Caicos Islands and Vietnam and removing Fiji, Samoa, and Trinidad and Tobago. Below is the official press release detailing these revisions and additional modifications. Taxation: Council updates the EU list of non-cooperative jurisdictions...

Slovenia gazettes Pillar 2 top-up tax return regulations

Slovenia published regulations governing the top-up tax return and the domestic top-up tax return in its Official Gazette on 13 February 2026. The measures form the country’s implementation of the global minimum tax under Pillar 2. The top-up tax return is used to declare top-up tax liabilities arising under the Income Inclusion Rule (IIR) or...