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Current News & Views

Note: Some EY documents require registration.

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

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

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

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

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

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

Saturday, September 5

  • Global: Comments published on revisions to model reporting rules for digital platforms (Deloitte) More

  • Australia: Software royalties: final taxation ruling and draft guidance (Tax authorities) More

  • Australia: Draft legislation for discretionary trust minimum tax and related measures (KPMG) More

  • Australia: Interim report finds that safeguard measures on fabricated structural steel unlikely to proceed (Deloitte) More

  • Korea: NTS announces Tax Administration Plan (Deloitte) More

  • Korea: Tax rulings and cases (August 2026) (Deloitte) More

  • Philippines: Incentives for electric vehicle production (KPMG) More

  • Singapore: Income tax treatment of loan waiver (Tax authorities) More

  • US: Final regulations: Deduction for qualified passenger vehicle loan interest enacted under OBBBA (KPMG) More

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

  • US: State tax matters (Deloitte) More

  • US: Tax news & views (Deloitte) More

Friday, September 4

  • Australia: CGT, trust taxation and real property reforms (Baker McKenzie) More

  • Croatia: Proposed tax measures to address inflation (KPMG) More

  • Egypt: New tax laws introduce VAT, income tax, dispute resolution, and stamp tax changes (KPMG) More

  • France: Management package gains remain exposed to salary taxation (Baker McKenzie) More

  • Italy: Pillar Two side-by-side package transposed into domestic law (Deloitte) More

  • Latin America: Latin American tax news (August 2026) (Joaquin Kersman) More

  • Malaysia: E-invoicing threshold increased to RM3 million effective September 1, 2026 (KPMG) More

  • Qatar: Qatar publishes first wave of implementing decisions for Global and Domestic Minimum Tax framework (EY) More

  • Saudi Arabia: Saudi Arabia issues procedural guide on tax and customs operations in Special Economic Zones (EY) More

  • Spain: Wealth tax exemption requires robust business evidence (Baker McKenzie) More

  • UAE: FTA introduces new input tax obligations (Baker McKenzie) More

  • Uruguay: Uruguay repeals QDMTT exclusion Decree and introduces compensation mechanism for taxpayers under stability clauses (EY) More

  • US: Federal Circuit narrows treaty-based FTC relief (PwC) More

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

  • US: Trade lines (EY) More

Thursday, September 3

  • Global: Comment on Art. 6.2.1 of GloBE rules (Lotfi Sellami Khelil on LinkedIn) More

  • Global: How early tax input improves outcomes in carve-outs (EY) More

  • Australia: Tax Ombudsman seeks feedback on tax administration review priorities and Director Penalty Notices (KPMG) More

  • Canada: Comment on Foresters case (Kevin Kelly on LinkedIn) More

  • China: Guangdong piloting advance tax rulings for large enterprises to support high-quality development in the Greater Bay Area (PwC) More

  • China: VAT treatment of non-taxable transactions (in Chinese) (Tax authorities) More

  • Curaçao: Parliament passes Pillar Two legislation (EY) More

  • Greece: Minister of Finance issues FY 2024 list of jurisdictions with preferential tax regime (Deloitte) More

  • Italy: Data centres and permanent establishments: Italy’s expanding enforcement meets treaty limits (Michele Dimonte and Francesco Olivieri, BonelliErede) More

  • Italy: Input VAT recovery deadlines extended (KPMG) More

  • Poland: Proposed amendments to income tax regulations; other tax developments (KPMG) More

  • US: US Customs and Border Protection issues notice seeking comment on heightened import disclosure and supply chain visibility requirements (EY) More

  • US: Will Side-By-Side survive a change in DC? (Alex Parker) More

Wednesday, September 2

  • Global: International tax news (August 2026) (PwC) More

  • Global: Pillar One: What began as a grand attempt to redraw the map of international taxation became an impressive demonstration of how difficult it is to move the world’s tax authorities from agreement in principle to agreement in practice (Lotfi Sellami Khelil on LinkedIn) More

  • Global: Two steps to challenge a transfer pricing benchmark (Borys Ulanenko on LinkedIn) More

  • Africa: Overview of recent tax developments (July / August 2026) (KPMG) More

  • Australia: Enactment of news media bargaining incentive law targeting large digital platforms (KPMG) More

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

  • Canada: CRA expands its EIFEL webpage to provide more detailed guidance on the financing (non borrowing-lending) IFE and IFR rules (Neal Armstrong) More

  • India: Retrospective application of amendment to fees for technical services limited (court decision); other direct and indirect tax developments (KPMG) More

  • Malaysia: New and updated service tax policies available on rental or leasing services (Deloitte) More

  • Thailand: Extension of reduced 7% VAT rate (Deloitte) More

  • UK: Can we fix it? Yes, we must! HMRC’s new error correction powers (Macfarlanes) More

  • US: Federal Circuit: Foreign tax credits under Canadian and French tax treaties cannot offset net investment income tax (KPMG) More

  • US: Proposed regulations address OBBBA amendments to s. 951 and 951A pro rata share rules (Deloitte) More

  • US: US CBP seeks comments on heightened import disclosure and supply chain visibility requirements (KPMG) More

  • Venezuela: Tax aspects of the OLH regulatory framework (Baker McKenzie) More​​​​​

 

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