Posts by: RF Report


Australia: ​​ATO consults on thin capitalisation compliance, risk-weighted asset allocation for foreign bank branches

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: Lok Sobha approves Finance Bill 2026 with amendments

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...

France releases form for statement of assessment of the supplementary (top-up) tax

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: Parliament approves law to implement DAC9, GIR MCAA

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 updates minimum tax act to reflect latest Pillar Two guidance, implements Side-by-Side package

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: MoF outlines treaty relief for foreign e-services profits

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-...

North Macedonia clarifies procedure for claiming loss carryforwards

The Public Revenue Office of North Macedonia has announced, on 12 March 2026, that companies subject to corporate income tax reporting a loss in their 2025 Tax Balance Sheet (Form “DB”) can carry the loss forward by submitting Form DD‑01 by 31 March 2026. A tax loss occurs when your company’s annual loss (shown with...

US: IRS introduces free options, resources for preparing and filing taxes in 2026

The US Internal Revenue Service (IRS) issued a notice on 20 March 2026 reminding taxpayers who still need to file their 2025 federal tax returns that free options and resources are available on IRS.gov. Whether taxpayers prefer to prepare their own returns or need assistance, IRS.gov offers secure electronic filing options. E-filing remains the fastest...

Malaysia clarifies taxation of real estate investment trusts (REITs), property trust funds (PTFs) to unit holders

The Inland Revenue Board of Malaysia (IRBM) released Practice Note No. 2/2026 (including examples) on 18 March 2026, addressing significant changes to how income distributions from real estate investment trusts (REITs) and property trust funds (PTFs) are taxed for most unit holders starting from the year of assessment (YA) 2026. The guidance was necessary because...

Hong Kong: IRD issues advance ruling on ship lessor qualification for preferential tax treatment

The Hong Kong Inland Revenue Department (IRD) published an advance ruling on 12 November 2025 on whether a Hong Kong ship leasing company qualifies for the concessionary tax regime for “qualifying ship lessors” under the Inland Revenue Ordinance. The Applicant, a wholly-owned subsidiary of Company A, operates exclusively as a ship lessor in Hong Kong....