Posts by: RF Report


UK: Foreign PE tax exemption to become mandatory from 2027 to block overseas loss relief against profits

The UK government has announced, on 21 May 2026, changes to the taxation of UK-resident companies who conduct part of their business through foreign permanent establishments (PEs). For most companies, it will be mandatory for profits and losses attributable to a foreign PE to be exempt from UK tax for accounting periods beginning on or...

Austria: Government approves tax reform bill with anti-fraud measures, new reporting rules

The Austrian government approved a draft bill introducing amendments to various tax laws on 20 May 2026. The draft bill is intended to promote tax fairness and combat tax fraud, while also reducing the tax burden on workers and simplifying administrative procedures. Income Tax Act (EStG 1988) The definition of “actual disposal” of assets is...

South Africa publishes GMT registration, notification external guide for gloBE implementation

The South African Revenue Service (SARS) has published the GMT Registration and Notification – External Guide (GMT-REG-01-G01) on 15 May 2026. SARS has introduced the Global Minimum Tax (GMT) as part of South Africa’s implementation of the Global Anti-Base Erosion (GloBE) framework. Registration for the Global Minimum Tax must be completed on the SARS eFiling...

Malawi enacts 2026–27 budget, introduces VAT on digital services by foreign companies

Malawi has enacted the legislation implementing the 2026–2027 Budget, which was published in the Official Gazette on 14 April 2026 and entered into force on 15 April 2026. This follows after Malawi’s Minister of Finance, Economic Planning and Decentralisation presenting the 2026-27 Budget Policy Statement to the National Assembly of Malawi on 27 February 2026....

Ireland: Irish Revenue updates VAT guidance on debt factoring, invoice discounting

Irish Revenue published eBrief 093/26 on 20 May 2026, updating the VAT Tax and Duty Manual on the VAT Treatment of Debt Factoring and Invoice Discounting. The update revises paragraphs 5 and Appendix 1 to reflect the CJEU judgment in Case C-232/24 (Kosmiro), with the amended guidance applying from the date of publication. The VAT...

Poland: Government proposes windfall tax on fuel sector amid Middle East crisis

Poland is moving to impose a temporary tax on extraordinary profits earned by liquid fuel producers and traders in 2026. The proposal, announced on 19 May 2025, responds directly to the geopolitical and economic fallout from the outbreak of armed conflict in the Middle East, which disrupted global oil supply chains and sent fuel prices...

Turkey extends May–June 2026 filing and payment deadlines for VAT, withholding, stamp tax returns

Turkey’s Revenue Administration has issued Tax Procedure Law Circular No. VUK-199/2026-5 on 15 May 2026, extending the filing and payment deadlines for several tax returns under the authority granted by Article 28 of Law No. 213 (Tax Procedure Law). The filing deadlines for Withholding and Premium Service Declarations, Accommodation Tax Declarations and Stamp Tax Declarations,...

Sweden: Court rules in favour of Kubal, overturns transfer pricing-based adjustment

Sweden’s Supreme Administrative Court has ruled in favour of Kubikenborg Aluminium AB (Kubal), overturning a transfer pricing-based adjustment made by the Swedish Tax Agency in a dispute concerning the deductibility of damages arising from an early termination of an electricity contract. The case, Kubikenborg Aluminium AB (Kubal) v. Skatteverket, decided on 19 May 2026, concerned...

Uruguay issues decree clarifying IRPF taxation of foreign-source income, assets, and withholding rules

Uruguay’s Ministry of Economy and Finance, through a Decree issued on 6 May 2026, has introduced detailed rules updating the taxation of income derived from non-resident entities under the Personal Income Tax (IRPF), in line with amendments set out in National Budget Law No. 20,446. The regulation seeks to strengthen legal certainty by clarifying the...

Hong Kong: IRD updates and expands FAQs on foreign-sourced income exemption rules

The  Hong Kong Inland Revenue Department has released additional and updated FAQs on the Foreign-Source Income Exemption (FSIE) regime. The FSIE regime, effective from 1 January 2023, provides tax exemptions for specified foreign-sourced passive income received in Hong Kong by in-scope multinational enterprise entities, subject to conditions such as economic substance requirements. The updated FAQs...