Posts by: RF Report


Korea (Rep.), Cambodia consider updating tax treaty

Korea (Rep.)’s National Tax Service reported that officials from Korea (Rep of.) and Cambodia held the 4th Korea-Cambodia Commissioners’ Meeting on 5 January 2026. The discussions focused on strengthening tax cooperation, including potential updates to the 2019 income tax treaty to incorporate measures for mutual assistance in tax collection. Korean officials highlighted the importance of...

US: IRS issues 2026 procedures for letter rulings, technical advice

The US Internal Revenue Service has issued Internal Revenue Bulletin 2026-01 on 29 December 2025, which includes five Revenue Procedures for 2026: letter rulings, determination letters, information letters and technical advice from the IRS. The bulletin outlines how the IRS provides rulings and technical advice across various tax areas and identifies the Associate Chief Counsel...

Ireland: MOF introduces corporation tax relief for unscripted productions

The Irish Ministry of Finance (MOF) has introduced a new corporation tax relief aimed at supporting the unscripted production sector, marking the first tax incentive in Europe dedicated exclusively to unscripted programming. Tánaiste and Minister for Finance Simon Harris T.D. and Minister for Culture, Communications and Sport Patrick O’Donovan T.D. unveiled the measure, which provides...

Ireland: Revenue updates TDM on Pillar 2 global minimum tax for multinationals, large domestic groups

Irish Revenue has published eBrief No. 010/26 on 8 January 2026, providing updates to Tax and Duty Manual (TDM) Part 04A-01-02 on the Global Minimum Level of Taxation for multinational enterprise groups and large domestic groups in the EU, covering the implementation of Ireland’s Pillar 2 global minimum tax rules. Tax and Duty Manual (TDM)...

Cambodia: ACAR announces 2025 financial statement submission deadlines

The Cambodia Accounting and Auditing Regulator (ACAR) has issued Notification No. 040/25 on 23 December 2025, outlining the requirements for enterprises and non-profit organisations to submit their 2025 financial statements in compliance with applicable accounting standards. Entities not subject to independent audit must submit their annual financial reports to ACAR by 20 April 2026. Organisations...

Korea (Rep.): 2026 tax reforms introduce QDMTT, higher corporate tax

The Korea (Rep.)’s 2026 tax reforms, enacted following budget-related amendments approved in December 2025, introduce several changes to corporate and individual taxation. Corporate tax rates are increased by 1% in each of the four brackets, and new brackets are established for the separate taxation of qualifying dividend income received by resident individuals. Other key measures...

Luxembourg: Tax Authority publishes Pillar 2 online filing guidance

The Luxembourg Administration of Direct Tax has issued guidance on Pillar 2 global minimum tax filings, covering registration and submission of Global Information Returns (GIR) and Supplementary tax returns. The guidance includes links to XML formats and related instructions. All filings must be completed online via MyGuichet.lu, which requires login. Procedures include: Registration Submission of...

Fiji joins OECD–Council of Europe mutual assistance convention

The Cabinet of Fiji approved the signing of the OECD–Council of Europe Convention on Mutual Administrative Assistance in Tax Matters, as updated by the 2010 protocol, on 6 January 2026. This marks the final step for the country’s removal from the European Union (EU) list of non-cooperative jurisdictions. Fiji was added to the EU Blacklist...

Hong Kong secures interim qualified status under domestic Pillar 2 regime

The Hong Kong Inland Revenue Department (IRD) updated its guidance on the global minimum tax and Hong Kong minimum top-up tax for multinational enterprise groups on 8 January 2026. The updates indicate that Hong Kong has received transitional qualified status for its Income Inclusion Rule (IIR), Hong Kong Minimum Top-up Tax (HKMTT), and Qualified Domestic...

UK: Treasury approves side-by-side framework for global minimum tax

The UK Parliament has released a statement from the Exchequer Secretary to the Treasury on 7 January 2026 endorsing the Side-by-Side arrangement for the Pillar 2 global minimum tax, recently agreed by the BEPS Inclusive Framework. Implementation in UK law will follow a technical consultation and will be included in the next Finance Bill, applying...