Posts by: RF Report


Bulgaria proposes higher VAT threshold to support small businesses

Bulgaria’s National Assembly is considering proposals to raise the mandatory Value Added Tax (VAT) registration threshold to EUR 85,000, up from the current level of around EUR 50,130–51,130. Members of parliament have submitted two separate proposals on the change.  The measures will now proceed to voting in two readings. A related draft law to amend...

Brazil, Spain confirm net equity interest treatment under tax treaty

Spain’s Ministry of Finance has announced that Brazilian interest on net equity, known as juros sobre o capital próprio (JCP), will be treated as interest under the 1974 tax treaty between Spain and Brazil. This clarification follows an exchange of diplomatic notes signed on 25 November 2025 and 12 March 2026 by the competent authorities...

Angola imposes 5% levy on foreign tourists

Angola will introduce a tourism levy on international travellers beginning in late July 2026, following the publication of Presidential Legislative Decree No. 4/26 on 30 April 2026. The Special Contribution for Tourism requires international visitors to pay 5% of their accommodation costs at classified tourist establishments, including hotels, resorts, and local lodging facilities. The charge...

US: IRS permits retroactive cost allocation refinement, setoff relief in transfer pricing case

In a Chief Counsel Advice memorandum dated 27 January 2026 and released publicly on 1 May 2026, the US Internal Revenue Service (IRS) ruled that a multinational corporation could retroactively adopt a more detailed cost allocation approach for intercompany services—and use the adjustment to claim setoff relief under federal transfer pricing regulations. According to the...

OECD updates GIR MCAA automatic exchange of GloBE information signatories list

The OECD published an updated list of signatories, including their signing dates, to the Multilateral Competent Authority Agreement on the Exchange of Global Anti-Base Erosion (GloBE) Information Returns (GIR MCAA) on 5 May 2026. The agreement facilitates the automatic exchange of GloBE Information Returns between tax authorities and reduces compliance costs for multinational enterprise groups...

Malta updates corporate income tax return for 2026 with transfer pricing, new reporting changes

Malta’s Commissioner for Revenue has announced that the electronic corporate income tax return for the year of assessment 2026 is now available through its online services. The supplemental document for Fiscal Units is also available for download. Several updates have been introduced to the tax return for the year of assessment 2026. On page 2...

Indonesia plans export duties and windfall tax on coal, nickel sectors

Indonesia is preparing to introduce export duties and a windfall tax on its coal and nickel sectors to help offset growing subsidy costs in the national budget, Finance Minister Purbaya Yudhi Sadewa announced on 4 May 2026. The minister explained that both commodities currently face zero export duties, which has created opportunities for under-invoicing and...

Bulgaria advances DAC8 and DAC9 transposition: Expands crypto reporting, Pillar Two exchange rules, transfer pricing framework

Bulgaria’s Council of Ministers has approved and submitted a draft bill to the National Assembly on 7 May 2026 to transpose two European Union directives into national law: Council Directive (EU) 2023/2226 (DAC8) and Council Directive (EU) 2025/872 (DAC9). The legislation also introduces amendments to the country’s transfer pricing framework. DAC8: Crypto-asset reporting requirements The...

Countries move into Pillar Two filing phase as first compliance deadlines approach

Tax authorities across several jurisdictions are accelerating the rollout of compliance systems for the OECD’s Pillar Two global minimum tax regime, with new filing portals, technical specifications, deferrals and reporting procedures now being introduced ahead of the first major deadlines in 2026. The developments reflect a broader global shift from policy design to administration and...

US: Trade Court rules Trump’s temporary tariffs illegal

A US trade court has ruled against President Donald Trump’s 10% temporary global tariffs, declaring them unlawful under a 1970s trade statute. However, the decision only blocks the duties for three specific parties, leaving them in effect for most importers. The US Court of International Trade delivered a 2-1 verdict stating that Trump’s use of...