Note: Some EY documents require registration.​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​

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Thursday, September 17

• Global: Transfer pricing – how credit ratings are assigned (David Zářecký on LinkedIn) More

• Australia: Draft legislation proposes phased discounts to replace the EV FBT exemption (Deloitte) More

• Australia: Exposure draft released for proposed R&D tax incentive reforms (Deloitte) More

• Canada: Canada introduces legislation to implement counter-tariffs (EY) More

• Canada: Canadian government announces new productivity mega deduction for capital investments (EY) More

• China: Latest individual income tax policies on (1) transfer of restricted shares of listed companies and (2) dividends and bonuses received by foreign individuals (PwC) More

• Netherlands: 2027 Tax Plan submitted to Parliament, includes full incorporation of Pillar Two side-by-side package (KPMG) More

• Nigeria: Updates to deep offshore oil and gas projects tax incentives framework (KPMG) More

• Philippines: Export-oriented enterprises (EOEs) with pending VAT zero-rating certification may be able to claim VAT refunds (Deloitte) More

• South Africa: Proposed digital VAT model: What businesses should understand (Deloitte) More

• US: Calculating QOZ gain recognition on December 31, 2026 (KPMG) More

 

 

Wednesday, September 16

• Global: New guidance on Global Minimum Tax framework (KPMG) More

• Australia: Weekly tax round-up (Deloitte) More

• Canada: Government introduces new Productivity Mega Deduction (Government) More

• Canada: Greater tax certainty for major investments in Canada: Advance Income Tax Rulings (AITR) program (Tax authorities) More

• China: Income obtained by individuals from transferring restricted shares of listed companies shall be taxed at a 20% rate (in Chinese) (Tax authorities) More

• Kazakhstan: Proposed tax measures for foreign e-commerce and electronic service providers (KPMG) More

• Netherlands: Budget Day 2026: real estate update (Loyens & Loeff) More

• Netherlands: Dutch Tax Plans 2027: a predictable package in a minority government setting (Loyens & Loeff) More

• Netherlands: Mandatory e-invoicing and digital reporting proposed for B2B transactions (KPMG) More

• Netherlands: Netherlands publishes budget proposals with key tax legislative updates for 2027 (EY) More

• Netherlands: The Hague Court of Appeal rules on arm's-length pricing of intragroup credit facilities with headroom (EY) More

• UK: UK VAT refunds for non-UK businesses in a VAT group (Tax authorities) More

• US: Updated automatic consent procedures simplify method changes for R&E expenditures and residential construction contracts (PwC) More

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Tuesday, September 15​

• Global: OECD Inclusive Framework Pillar Two package addresses consistency of rule application and reporting (PwC) More

• Australia: Consultation on draft legislation introducing 2026-27 budget tax reform measures, including R&D tax incentive simplification (KPMG) More

• Australia: Software and royalty withholding tax risk - ATO releases draft PCG (Deloitte) More

• Belgium: Rulings on copyright tax regime: Retroactive application for computer programs (Deloitte) More

• Colombia: Colombia clarifies reinvestment requirement under Colombia-Spain tax treaty dividend provisions (EY) More

• Colombia: Reconstruction decree and tax rulings (Baker McKenzie) More

• Mexico: Proposed tax measures in 2027 Economic Package (KPMG) More

• Netherlands: Unrealized losses may be forfeited following a change in shareholders (Supreme Court decision) (KPMG) More

• Poland: Debit note does not allow VAT deduction after limitation period expires (Supreme Administrative Court decision); other tax developments (KPMG) More

• Switzerland: Swiss Supreme Court confirms transfer pricing adjustments can have major VAT implications, especially for businesses with limited VAT recovery (Baker McKenzie) More

• US: IRS eases accounting method changes for R&E expenditures and residential construction contracts (Alvarez and Marsal) More

• US: Trade lines (EY) More

• US: US Tax Court: Taxpayer’s section 245A dividends received deduction limited under section 246(c)(1) to dividends on shares directly held by the taxpayer (KPMG) More

• Vietnam: Amendments to customs law enacted (KPMG) More

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Monday, September 14​

• Global: Public comments on OECD’s model reporting rules for digital platforms (OECD) More

• Global: Tax Policy Reforms 2026 report (OECD) More

• China: Announcement on VAT withholding on certain services provided by domestic individuals (in Chinese) (Government) More

• EU: A&P Deco case (Application of EU VAT Directive to transfers of businesses and related leasing arrangements) (EGC decision) More

• Finland: Bill to implement tax changes (in Finnish) (Government) More

• Hungary: Guidance on 2025 changes to OECD Model Treaty and Commentary (in Hungarian) (Tax authorities) More

• Mauritius: Regulations which provide detailed rules for applying QDMTT (Government) More

• Poland: Draft bill to impose higher tax burden on energy sector (in Polish) (Government) More

• Saudi Arabia: Procedural guide on tax and customs operations in 4 SEZs (in Arabic) (Government) More

• Uruguay: Decree introducing mechanism to compensate taxpayers covered by stability clauses (in Spanish) (Government) More

• US: Bruyea case (Whether foreign tax credits under double tax treaties can be used to offset US’s net investment income tax) (Court decision) More

• US: Christensen case (Whether foreign tax credits under double tax treaties can be used to offset US’s net investment income tax) (Court decision) More

• US: Proposed regulations relating to allocation and apportionment of deductions to foreign source section 951A category income (Government) More

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Saturday, September 12

• Global: Administrative Guidance on GloBE rules: Explicitly Conditional Taxes and the use of local financial accounting standard under a QDMTT in case of mismatching fiscal periods (OECD) More

• Global: OECD Pillar Two: Updated version of GIR released (Deloitte) More

• Global: OECD releases new Pillar Two guidance, updated GIR and framework for legislative reviews (Loyens & Loeff) More

• Global: PE watch: Latest developments and trends, September 2026 (EY) More

• Global: UN: 2025 update to UN Model Tax Convention (KPMG) More

• Global: Updated GloBE Information Return released as part of new Pillar Two implementation package (KPMG) More

• Australia: Australian Taxation Office finalizes software royalties ruling and expands compliance approach (EY) More

• Australia: Legislation amending foreign resident capital gain tax, merger control regimes passed by Parliament (KPMG) More

• Denmark: Updated dividend withholding tax refund procedure (KPMG) More

• EU: E-News from KPMG’s EU Tax Centre (KPMG) More

• EU: Public consultation on alignment of VAT rules with circular economy (KPMG) More

• EU: EU trade update (Deloitte) More

• Germany: Application of minimum taxation rules resulting in permanent loss of tax loss carryforwards upheld (Federal Fiscal Court decision) (KPMG) More

• Netherlands: Dutch Supreme Court: unrealised losses fall within the loss restriction rules upon a share transfer (Loyens & Loeff) More

• Netherlands: Public consultation on revision of treaty policy regarding service payments (in Dutch) (Government) More

• Romania: "TechUp Romania" scheme enacted (KPMG) More

• Serbia: Amendments to corporate income tax law (KPMG) More

• US: Proposed rules address OBBBA expense apportionment of deductions to foreign source income (PwC) More

• US: Report on recent US international tax developments (EY) More

• US: State tax matters (Deloitte) More

• US: US revises section 338 tariffs on Canadian goods and imposes targeted import bans (PwC) More​

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Friday, September 11​

• Belgium: Tax authorities clarify updated BEPS 13 transfer pricing forms and CbC reporting (Deloitte) More

• Canada: CRA finds that entering into an employment contract indemnifying an employee against reportable-transaction penalties was not a reportable transaction (Neal Armstrong) More

• China: Tax brief (August 2026) (Ascentium) More

• India: One-time compensation received for diminution in value of stock options not taxable employment income (tribunal decision) (KPMG) More

• Malaysia: Recent tax developments concerning indirect tax, transfer pricing, and e-invoicing (KPMG) More

• Mexico: 2027 economic package submitted to Chamber of Deputies (Deloitte) More

• Philippines: Updated guidelines for tax audit program (KPMG) More

• UK: Knights Developments case: Property developer profits taxable in UK under Article 6 of Isle of Man income tax treaty (Upper Tribunal decision) (KPMG) More

• US: IRS expands safe harbour for section 45Q carbon sequestration credit (PwC) More

• US: Measure twice, elect once: modeling section 987 relief before committing (PwC podcast, 33 mins) More

• US: Proposed regulations: Allocation and apportionment of deductions to foreign source section 951A category income and DEI (KPMG) More

• US: Proposed regulations: Qualified opportunity fund (QOF) reporting and certification procedures (KPMG) More

• US: US Tax Court: Final partnership adjustment held timely under BBA limitations period rules (KPMG) More

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Thursday, September 10

• Global: Global indirect tax news (Deloitte) More

• Australia: Comments on Hilton Part IVA (GAAR) case: A strong commercial outcome does not, by itself, explain the tax structure used to achieve it (Neil Pereira on LinkedIn) More

• Australia: Comments on Hilton Part IVA (GAAR) case: Did Hicks check out of Hilton too soon? (Stuart Landsberg on LinkedIn) More

• Australia: Guidance on reintroduced loss carry back tax offset (KPMG) More

• Australia: The ATO has reversed its trend of anti-avoidance MNE losses in recent years in Pepsi, Mylan and Minerva with its Part IVA (GAAR) win in Hilton (Andy Bubb on LinkedIn) More

• Australia: Weekly tax round-up (Deloitte) More

• Canada and US: US announces import bans and modified tariffs on Canadian alcoholic beverages, dairy, and motor vehicle-related products (KPMG) More

• Canada and US: US bans certain Canadian alcoholic beverages, dairy and motor vehicle products under section 338; modifies scope of existing 50% duties (EY) More

• France: Comments on Ariston transfer pricing case (David Zářecký on LinkedIn) More

• India: Consideration in excess of FMV received upon issuance of convertible debentures not taxable income (tribunal decision) (KPMG) More

• UK: Tax investigations and disputes newsletter (Macfarlanes) More

• US: Federal Circuit Court of Appeals holds taxpayers may not offset US net investment income tax with foreign tax credit (EY) More

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Wednesday, September 9

• Global: A wrong website can ruin a transfer pricing benchmark before the review even starts (Borys Ulanenko on LinkedIn) More

• Global: E-invoicing developments tracker (EY) More

• Global: Global tax talk – tax in 60 seconds (Will Morris on LinkedIn) More

• Global: Trade talking points (EY) More

• Australia: 30% Minimum tax on discretionary trusts: Exposure draft legislation released (Deloitte) More

• Australia: ATO software ruling finalized: What next? (Deloitte) More

• Australia: Tranche 2: Negative gearing and new residential dwellings legislation (Deloitte) More

• Australia: Tranche 2 draft legislation: Capital gains tax (Deloitte) More

• Canada: Canada extends suspension of federal excise tax on fuel (EY) More

• Canada: Harvard Properties case – Federal Court of Appeal finds in a section 160 context that the FMV of a note and preferred shares equaled the cash amount that their transferee agreed to pay for them (Neal Armstrong) More

• Colombia: Introduction of national carbon market regulatory framework, including national carbon tax (KPMG) More

• EU: Information powers of authorities and fundamental principles of law under the EU court’s microscope (Jonathan Schwarz) More

• France: FTA issues new guidelines on extension of exceptional temporary surtax (Deloitte) More

• Greece: Draft bill proposes foreign direct investment incentive regime (Deloitte) More

• Pakistan: Recent guidance on income tax, sales tax, and customs duties (KPMG) More

• Poland: Proposed temporary corporate tax rate increase for energy and fuel sectors; other tax developments (KPMG) More

• Switzerland: Future tax reforms boost competitiveness strategy (Baker McKenzie) More

• UK: Promoting the UK as a Treasury Centre (Slaughter and May) More

• US: 1% floor on charitable deductions may erode NOL carryovers (KPMG) More

• US: Automatic accounting method change procedures for R&E expenditures under Rev. Proc. 2026-32 (KPMG) More

• US: IRS accepting applicants for 2027 CAP program beginning September 8 (KPMG) More

• US: Trump proposes tariffs on generic pharmaceuticals – what companies should know (PwC) More

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Tuesday, September 8​

• Global: Pillar Two and transactions: why Pillar Two can no longer be an afterthought in M&A (Ross Robertson on LinkedIn) More

• Global: When a permanent establishment disappears, what happens to the hidden gains? (Marco Mosconi on LinkedIn) More

• Canada: Comment on Husky Energy case – beneficial ownership under Canada / Luxembourg treaty (Błażej Kuźniacki on LinkedIn) More

• EU and UK: TOGCs and leases - a rich tapestry (Slaughter and May) More

• Taiwan: Business tax obligations of Taiwanese taxpayers which purchase inbound digital services from foreign suppliers (Tax authorities) More

• UK: Branching out: what the Barclays case means for UK VAT grouping (Macfarlanes) More

• US: Lights, camera...tax breaks! (Alex Parker) More

• US: President endorses data center development, entertainment tax incentive (Deloitte) More

• US: Trade corner (Deloitte) More

• US: Treasury, IRS release wave of tax guidance (Deloitte) More

• US: US Federal Circuit Court of Appeals finds that Art. XXIV of the Canada / US treaty did not create a right to an FTC independent of the Code provisions (Neal Armstrong) More

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Monday, September 7​

• China: End of tax exemption on certain dividends and bonuses paid to foreign individuals (in Chinese) (Government) More

• Greece: Draft bill on new incentives for foreign direct investment (in Greek) (Government) More

• Hong Kong: Sinolink case (Debt vs. equity characterisation) (Court decision) More

• India: LG Electronics case (Deputation (i.e., secondment) of expatriate employees from Korean parent to Indian subsidiary: “fixed place of business” PE under India / Korea treaty?) (Tribunal decision) More

• Ireland: Updated guidance on GloBE rules (pre-transition current and deferred tax adjustments) (Tax authorities) More

• Netherlands: Government’s appraisal of EU’s Omnibus proposal (in Dutch) (Government) More

• New Zealand: Draft guidance on characterisation of outbound software payments (Tax authorities) More

• Qatar: Decisions implementing administrative aspects of GloBE rules, including currency conversion rules, simplified reporting procedures, and transitional CbC reporting safe harbour (Tax authorities) More

• Sweden: Bill to amend administrative rules on reporting of dividend withholding tax (in Swedish) (Government) More

• UK: Knights Developments case (Trading profits from land development in UK: applicability of Art. 6 and Art. 13 of Isle of Man / UK double tax treaty) (Court decision) More​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​