Sunday, June 07, 2026
Panama has enacted Law No. 526 of 28 May 2026, significantly reforming its National Fiscal Code by introducing economic substance requirements for multinational enterprise (MNE) groups earning foreign-source passive income. The reform is designed to strengthen tax transparency, align with international standards, and support Panama’s removal from the EU list of non-cooperative jurisdictions. The measures...
The OECD has released an updated 2026 Consolidated Commentary to the Global Anti-Base Erosion (GloBE) Model Rules on 28 May 2026, incorporating administrative guidance issued by the Inclusive Framework between March 2022 and January 2026. Addressing the tax challenges arising from the digitalisation of the economy has been a key priority of the OECD/G20 Inclusive...
The Inland Revenue Board of Malaysia has issued Public Ruling No. 3/2026 on 22 May 2026, guiding the application of bilateral and unilateral tax credits where a Malaysian tax resident is subject to taxation in both Malaysia and a foreign jurisdiction, resulting in double taxation. The ruling explains the eligibility requirements, methods for calculating the...
Argentina will gradually eliminate export taxes on several industrial sectors over the next 12 months starting in July 2026, according to the economy ministry. Export duties on automotive, petrochemical, chemical, rubber and machinery products—currently set at 4.5%—will be reduced by 0.375 percentage points each month until they reach zero. The phased approach is designed to...
Romania’s tax authority, the National Agency for Fiscal Administration (ANAF) announced, on 28 May 2026, that it has proposed amendments to ANAF Order no. 3562/2024, which governs the procedures for redirecting corporate profit tax toward sponsorships and mecenat acts. Key changes include implementing a notification system for instances where requested amounts exceed legal limits, allowing...
The European Commission published a new frequently asked question (‘FAQ’) on 28 May 2026, which affirms that all EU Member States must treat Cyprus as having a qualified income inclusion rule under the EU Pillar Two Directive. The income inclusion rule ensures that EU Member States apply the minimum tax to the foreign subsidiaries of...
Sweden’s Ministry of Finance has issued a memorandum Fi2026/0119 on 25 May 2026 proposing amendments to the rules on Qualified Domestic Minimum Top-Up Tax (QDMTT) under the Minimum Taxation Directive (2022/2523), aimed at changing how joint ventures and their subsidiaries are treated for Pillar Two purposes. Under the proposal, a joint venture resident in Sweden...
The Swedish Tax Agency has updated its guidance on Global Minimum Tax (Additional Tax) obligations to reflect the OECD’s common understanding on flexible approaches for central filing of the GloBE Information Return (GIR) published on 18 May 2026. The update provides clarification for large domestic and multinational groups subject to the Top-up Tax Act (2023:875),...
Albania has ratified the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI) through Law No. 45/2026, published in the Official Gazette on 20 May 2026. The law gives effect to Albania’s commitment under the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) to implement the...
The Portuguese Tax and Customs Authority has issued guidance on the filing of the Information Return on the Top-Up Tax (GIR return) under the Global Minimum Tax Regime (GMTR/Pillar Two), following a common understanding published by the OECD on 18 May 2026. The clarification addresses circumstances in which resident entities may benefit from relief from...