We share the latest bite-sized information and updates from Singapore and around the region.
Tax News
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Singapore updates
IRAS has announced that selected digital services on its website will be unavailable from 16 December 2026, and all digital services on myTax Portal will be unavailable from 22 to 28 December 2026.Taxpayers are informed to complete relevant digital service transactions before the downtime or when digital services resume on myTax Portal after 29 December 2026 8:00 AM.
IRAS webpage 'Travel industry' has been enhanced for readability and reorganised to highlight the GST treatment for travel arranging services.
IRAS webpage 'Customer Accounting for Prescribed Goods' has been enhanced and reorganised for readability.
IRAS webpage 'Consultancy and Professional Services' has been enhanced for better readability, with an additional example of a service that qualifies for zero‑rating.
IRAS webpage on the 'Assisted Self-help Kit (ASK)' has been reorganised and enhanced for readability.
IRAS issued a media statement 'IRAS Warns Against False, Incorrect or Unsupported Employment Expense Claims' advising taxpayers against relying on misleading information encouraging false claims for employment offences.
IRAS published a webpage '3 Things to Know For Corporate Income Tax Filing 2026' which highlights:
- key tax rebates, cash grants and enhanced deductions available to corporate taxpayers in YA 2026,
- digital tools and guidance available on the IRAS website to help taxpayers,
- key dates in the filing and assessment process.
IRAS has updated the webpage 'Gifts and Samples' to include a clarification that associated costs can be excluded when determining whether the total cost of gifts exceeds $200.
IRAS announced that more than 323,000 companies, including over 37,000 newly incorporated companies, will benefit from an expanded and enhanced suite of digital self-help resources when filing their CIT Returns for YA 2026.
IRAS published GST eDM (Issue 11) on the following topics:
- Check your GST InvoiceNow Implementation Date
- $226 million recovered through GST audits in FY2025/2026
- Beyond Tax Invoices: Input Tax Claims Must Be Supported by Genuine Business Transactions.
On 16 October 2026, IRAS revised the introductory paragraph on its webpage ‘Compensation’ to distinguish compensatory payments from consideration for a supply, and added new examples of payments that are compensatory in nature.
On 16 October 2026, IRAS updated its webpage ‘Tax Treatment of Business Expenses (G-L)’ to provide guidance on the deduction for qualifying expenditure incurred on qualifying green certificates and green credits which is available from YA 2026. It correspondingly removed guidance on the deduction of carbon credits.
On 14 October 2026, the IRAS updated its webpage "Importing of Goods" to reorganise contents into clearer sections on import GST calculation and payment, clarify when GST on imports is not required, and integrate error guidance into the respective sections.
On 14 October 2026, the IRAS updated its webpage "Supplying to overseas customers with local delivery address" to add a new section on required export documents, consolidate the FAQ content into a common scenarios table with a new scenario added and for better readability.
The IRAS updated its webpage “Global Anti-Base Erosion (GloBE) Rules and Domestic Top-up Tax (DTT)” on 13 October 2026 to reflect the implementation of the Substance-based Tax Incentive Safe Harbour in Singapore. The IRAS has also published a list of Qualified Tax Incentives for the purpose of the Substance-based Tax Incentive Safe Harbour.
Singapore and the Kyrgyz Republic signed an Avoidance of Double Taxation Agreement (DTA) on 12 October 2026. However, this Agreement is not yet ratified and therefore does not have the force of law. The full text of the DTA is available on here.
The IRAS updated its webpage on “Tax obligations of non-resident public entertainer”, specifically FAQs, to distinguish tax filing obligations and Notice of Assessment expectations across different work pass types.
The IRAS enhanced its webpage on GST “Purchasing Remote Services from Overseas Service Providers” for readability, with remote services reorganised into a categorised table, customer obligations consolidated under a dedicated section, and penalty information surfaced as a standalone section.
The IRAS enhanced its webpage on “Goods and Services Tax (GST): What It Is and How It Works” for readability, with new sections added on what GST is, why Singapore has GST, and how GST works, including a worked example illustrating the GST mechanism through the supply chain.
The IRAS updated its webpage on “Country-by-Country Reporting (CbCR)” to add Antigua and Barbuda to the list of jurisdictions that have exchange relationships with Singapore.
The IRAS enhanced its webpage on GST “Due Dates and Requests for Extension” for readability, with clarifications added on GIRO deduction dates, extension request eligibility, and refund timelines and payment methods.
Income Tax (Deduction for Expenditure on Green Certificates and Green Credits) Rules 2026 was first published in the Government Gazette on 7 October 2026.
Following the publication on 8 September 2026 of the Finance (Income Taxes) Bill 2026 (Bill) which covered amendments to the Income Tax Act 1947, the Multinational Enterprise (Minimum Tax) Act 2024, and the Economic Expansion Incentives (Relief from Income Tax) Act 1967, and related amendments to the Goods and Services Tax Act 1993 and the Property Tax Act 1960, the Bill passed its second reading in Parliament on 6 October 2026.
On 6 October 2026, the IRAS published a new webpage on the GST treatment of fees charged by migrant domestic worker employment agencies.
In a forum reply, IRAS reassured that platform workers will not be penalised if their tax assessments need to be revised as a result of incomplete or inaccurate information submitted by intermediaries.
Philippines Department of Finance announced on 2 October 2026 that negotiations for an updated tax treaty with Singapore had just been concluded.
The IRAS added a new e-Learning video for the Year of Assessment (YA) 2026 webinar. The webinar video cover the Corporate Income Tax filing process and general corporate tax treatment concepts.
On 1 October 2026, the IRAS published a summary of a ruling on whether the gains from the sale of the Properties (defined in the summary) are capital in nature and not income subject to tax under the Income Tax Act 1947.
On 1 October 2026, the IRAS published a summary of a ruling on whether the the gains arising from the transfer of intellectual property rights are taxable under Section 10(1) of the Income Tax Act 1947. The IRAS ruled that the transfer was capital in nature and the gains were therefore not taxable, as the transfer formed part of an internal group reorganisation and resulted in the complete sterilisation of the company's profit-making apparatus. A balancing charge would, however, arise on the Section 19B intellectual property rights.
On 1 October 2026, the IRAS published a summary of a ruling on whether the redeemable, non-convertible, non-cumulative, participating, non-voting preference shares (RPS) to be issued by Company A to the Subscribers will be treated as equity for Singapore income tax purposes, and whether dividends received by the Subscribers on the RPS will be exempt from tax under the Income Tax Act 1947.
The IRAS enhanced its webpage on GST “Prevailing GST rate” for readability and updated to include the current GST rate of 9% from 1 January 2024 onwards.
The IRAS enhanced its webpage on GST “Motor Vehicles Expenses” for readability, with content reorganised to better explain input tax restrictions and exceptions for motor vehicles and related expenses, and the definition of 'motor car' has been incorporated for easier reference.
The IRAS enhanced its webpage on GST “Keeping Records” for readability and reorganised to improve the flow of information on record-keeping requirements.
The IRAS enhanced its webpage on GST “Sale of Motor Vehicles” for readability and restructured to focus on output tax treatment for the sale of motor vehicles, including whether the taxpayer is a motor vehicle dealer and whether it is a new or second-hand vehicle.
The Business Expense Deductibility Checker is now available on the IRAS website. Companies may use this tool to determine the tax deductibility of common business expenses incurred, providing them with greater clarity and confidence when preparing tax computations.
The IRAS enhanced its webpage on GST “Travellers bringing goods into Singapore” for readability, with new sections added on eligibility for GST import relief, pre-arrival guidance, and steps to declare and pay GST upon arrival in Singapore.
The IRAS enhanced its webpage on GST “Foreign currency transactions and foreign exchange gains or losses” for readability, with new sections added on approved exchange rate sources, how to handle different transaction types, and what counts as exchange gains or losses.
The IRAS enhanced its webpage on GST “Sale and disposal of business assets” for readability and included a section on the conditions to fulfil to treat disposed assets as having no market value.
The IRAS enhanced its webpage on GST “Discounted Sale Price Scheme” for readability, with eligibility requirements consolidated into a single section.
The IRAS enhanced its webpage on GST “Out-of-scope supplies” for readability, with content restructured into clearer sections and types of out-of-scope supplies and a consolidated section on supporting documents to keep.
The IRAS enhanced its webpage on GST “Displaying and quoting prices” for readability, with content restructured into clearer sections and tables for acceptable and unacceptable price display formats.
Previously on 4 June 2026, the IRAS published an update of the Transfer Pricing Guidelines (Ninth Edition) clarifying the treatment of share-based compensation (SBC) costs for transfer pricing purposes effective from YA 2026. This includes a concession to exclude uncharged and notional SBC costs from the calculation of taxable service income for Singapore transfer pricing purposes.
On 25 September 2026 IRAS provided another update to this topic, extending the concession retroactively to YAs 2022 to 2025, as a one-off measure, provided the following conditions are met by taxpayers:
- taxpayers have to submit revised tax computations showing full details of the mark-up on uncharged and/or notional SBC costs, and
- these are to be submitted by
- 15 November 2026 for YA 2022, and
- 28 February 2027 for YAs 2023 to 2025.
In such cases IRAS is also prepared to waive the section 34E surcharge on related transfer pricing adjustments, if any.
Given the limited timeframe, this is a good opportunity for multinational companies with SBC arrangements in place to revisit the positions taken in respect of the SBC costs in the past Singapore income tax returns and decide whether the concession should be pursued.
The IRAS published a flowchart to provide guidance on how the expressions ‘directly in connection with’ or ‘directly benefit’ should be used to determine if services supplied to a person outside Singapore qualifies for GST zero-rating.
IRAS updated is webpage 'Benefits Relating to Loans' to include the government interest rates applicable for FY 2026 (1 April 2026 to 31 March 2027).
A corrigendum has been published to the Income Tax (International Tax Compliance Agreements) (Common Reporting Standard) (Amendment) Regulations 2026, correcting a drafting error in regulation 8(f). The date specified in new regulation 15(7A) has been amended from 31 December 2016 to 31 December 2026.
The Goods and Services Tax Act 1993 - Goods and Services Tax (General) (Amendment No. 3) Regulations 2026 has been published on 18 September 2026 by aligning definitions with the Casino Control Act 2006, adding definitions for "electronic credit transfer" and "electronic credits". A new regulation clarifies that references to "casino chips" exclude electronic credits. Regulation 92E is expanded to include bets made through electronic credit transfers of complimentary electronic credits given by the casino operator in the computation of GST chargeable on gaming supplies.
The IRAS has revised Annex B – Summary of GST Implications to the e-Tax Guide to clarify the treatment of GST refunds and the transitional rules on input tax claims.
This Order came into operation on 11 September 2026. It amends the Ninth Schedule to the Income Tax Act 1947 to include 'Small and Medium Enterprise (SME) Cash Grant 2026' as a specified public scheme under section 6(11A).
This Order came into operation on 11 September 2026. It amends the Second Schedule to the Inland Revenue Authority of Singapore Act 1992 to include the Small and Medium Enterprise (SME) Cash Grant 2026 as a 'scheduled public scheme'.
This Order came into operation on 11 September 2026. It amends the Sixth Schedule to the Goods and Services Tax Act 1993 to include 'Small and Medium Enterprise (SME) Cash Grant 2026' as a public scheme under section 6(6C).
On 31 July 2026, the Monetary Authority of Singapore issued a circular FDD Cir 05/2026 titled “Tax Incentive Schemes for Funds”, providing updates to the fund tax incentive schemes under sections 13D, 13O, 13OA and 13U of the Income Tax Act 1947 for non-single family office (non-SFO) funds as well as SFO funds.
IRAS has updated its webpage to clarify companies' filing obligations when a change in financial year end results in their financial periods spanning two years of assessment.
The Finance (Income Taxes) Bill 2026 was published on 8 September 2026. It proposes amendments to the Income Tax Act 1947, the Multinational Enterprise (Minimum Tax) Act 2024, and the Economic Expansion Incentives (Relief from Income Tax) Act 1967, and related amendments to the Goods and Services Tax Act 1993 and the Property Tax Act 1960.
The Ministry of Finance’s responses to feedback received in the public consultation of the draft bill can be found here.
The Income Tax (Exemption of Interest and Other Payments for Economic and Technological Development) (Miscellaneous Amendments) Notification 2026 (S 587 of 2026) came into operation on 9 September 2026. It mainly extends the sunset dates for exemptions provided for in following Notifications:
- Income Tax (Exemption of Interest and Other Payments for Economic and Technological Development) Notification (N 13)
- Income Tax (Exemption of Interest and Other Payments for Economic and Technological Development) (No. 2) Notification 2001 (G.N. No. S 257/2001)
- Income Tax (Exemption of Interest and Other Payments for Economic and Technological Development) (No. 3) Notification 2003 (G.N. No. S 500/2003)
- Income Tax (Exemption of Interest and Other Payments for Economic and Technological Development) Notification 2012 (G.N. No. S 72/2012)
- Income Tax (Exemption of Interest and Other Payments for Economic and Technological Development) Notification 2013 (G.N. No. S 5/2013)
- Income Tax (Exemption of Interest and Other Payments for Economic and Technological Development) (No. 2) Notification 2018 (G.N. No. S 801/2018)
On 4 September 2026, IRAS published its annual report for FY2025/26 with the following details:
- $97.3 billion in tax revenue collected to support Singapore’s growth, with strong compliance and low arrears
- $1.2 billion in enterprise grants processed to support over 126,000 businesses
- Digital as the default for a more seamless tax experience:
- Progressively bringing GST-registered businesses onto e-invoicing
- Close to 1 million taxpayers receiving tax bills directly
- Near-total adoption of digital payment services
On 3 September 2026, IRAS issued a media release that the Singapore Ministry of Defence (MINDEF) has worked with the IRAS to rectify incorrect NSman tax relief amounts that were granted to approximately 15,000 taxpayers, comprising NSmen as well as eligible parents and spouses, across the Income Tax Years of Assessment (YA) 2025 and 2026.
On 3 September 2026, IRAS updated its “Tax on Supplementary Retirement Scheme (SRS) withdrawals” webpage that, with effect from 1 Jul 2026, the statutory retirement age will increase from 63 to 64.
On 2 September 2026, the Ministry of Finance (“MOF”) has published a summary of responses to public consultation on the proposed Finance (Income Taxes) Bill 2026. The proposed Bill covered amendments to the Income Tax Act 1947 (“ITA”) and Multinational Enterprise (Minimum Tax) Act 2024 (“MMTA”).
The key responses received on the proposed amendments to the ITA are in relation to the following:
- Enhancement of the Enterprise Innovation Scheme (“EIS”) to support businesses in adopting artificial intelligence;
- Requirement for companies to use IRAS’ e-service to file objections and revisions to their tax assessments; and
- Standardisation and extension of the timeline for appeals against Board of Review decisions to the General Division of the High Court.
The key responses received on the proposed amendments to the MMTA are in relation to Singapore’s implementation of the GloBE information return exchange framework.
On 2 September 2026, IRAS published a new webpage on the income tax treatment of deposits under the Beverage Container Return Scheme (BCRS).
The Inland Revenue Authority of Singapore (IRAS) published a seventh edition of its e-Tax Guide " GST: Renewal of ACAP Status" on 1 September 2026 to provide clarifications and updates, including:
- To provide clarity that ACAP renewal reviews should include a review of the application of partial exemption rules on the recovery of input tax by partially exempt businesses, and amend paragraph 3.9 of “Appendix 1: GST ACAP Renewal Review Guidance";
- To update on additional information to be provided in “Section 1: Business Information” of the ACAP Renewal Report, and amend “Appendix 1: GST ACAP Renewal Review Guidance";
- To refer to the guidelines on information to be provided in requests for technical clarifications and amend "Appendix 1: GST ACAP Renewal Review Guidance".
The Inland Revenue Authority of Singapore (IRAS) published a sixth edition of its e-Tax Guide " GST: Assisted Compliance Assurance Programme (ACAP)" on 1 September 2026 to, amongst others, prescribe guidelines on the information to be provided in requests for technical clarifications and amend “Appendix 1: GST ACAP Review Guidance”.
On 1 September 2026, the IRAS published a summary of a ruling on whether the intended waiver of loan by Company A (“Lender”) is a capital transaction and hence, any gains arising therefrom is not subject to tax under the provisions of the Income Tax Act 1947 (“ITA”).
On 1 September 2026, the IRAS published a summary of a ruling on whether the tax deferred distributions derived from a foreign trust will be subject to tax in Singapore.
On 1 September 2026, IRAS has published a new webpage setting out the information that tax agents should provide when submitting GST technical clarification requests on behalf of taxpayers. From 1 September 2026, tax agents should refer to the guidelines on the webpage and include the required information in their submissions.
On 31 August 2026, IRAS updated its “Enterprise Innovation Scheme (EIS)” webpage to provide information on the new EIS qualifying activity (i.e. AI adoption) and reflect the formation of the Skills and Workforce Development Agency, following the merger of SkillsFuture Singapore and Workforce Singapore on 1 July 2026.
The Inland Revenue Authority of Singapore (IRAS) published a third edition of its e-Tax Guide " Enterprise Innovation Scheme (EIS)" on 31 August 2026. Key updates include:
- Enhancements to the EIS as announced in Budget 2026:
- Expanding the list of qualified partners to include the Sectoral AI Centre of Excellence for Manufacturing
- Introducing a new qualifying activity for the adoption of AI
- Updates to references from “SkillsFuture Singapore” to “Skills and Workforce Development Agency”, following the merger of SkillsFuture Singapore and Workforce Singapore on 1 July 2026.
The package comprises three measures:
- A tax exemption for profit-related returns arising from the provision of fund management services to funds that qualify for tax exemption under sections 13D, 13O, 13OA, 13U or 13V of the Income Tax Act 1947. Ordinary income such as salaries and bonuses from employment are excluded from the scope of the exemption. The proposed tax exemption is expected to take effect from the Year of Assessment 2027, and further details will be announced in Budget 2027.
- A new hedge fund investment programme under which the Government will invest alongside hedge fund managers that are committed to establishing or deepening their presence in Singapore, with a view to supporting the broader growth of Singapore’s hedge fund ecosystem.
- A new Investment Management Track under the Overseas Networks & Expertise (ONE) Pass framework which would refine how the salary criteria are assessed to better reflect industry compensation structures, with a view to attracting top global leaders and senior investment professionals in the asset management industry.
Further details will be announced for (2) and (3).
Singapore's timely and quick actions in light of recent developments in other financial hubs demonstrate its willingness to remain agile, consider industry’s feedback and respond to developments in the global marketplace. This is a hallmark of Singapore Inc that is recognised by global investors and firms around the world. Majulah Singapura.
The IRAS issued “GST: Time of Supply Rules (Sixth Edition) to reflect the renumbering of regulations 16 and 20 under the GST(General) Regulations.
In Modernland Overseas Pte Ltd v Comptroller of Income Tax and another matter [2025] SGHC 239, the taxpayer issued certain Amended Notes pursuant to a debt restructuring scheme. In an advance ruling the Singapore tax authority held that the Amended Notes were not the same debt instrument as before and could not qualify for the Qualifying Debt Securities (QDS) scheme. The taxpayer sought a declaratory relief from the General Division of the High Court that would allow the Amended Notes to retain the QDS status after restructuring. However, the taxpayer failed in its application as the Court found that the Amended Notes were not mere amendments of the Existing Notes (which had qualified as QDS) but were entirely new debt instruments, as the original notes were expressly cancelled and replaced under the restructuring scheme.
On 9 July 2026, the taxpayer's appeal against the above decision were dismissed by the Appellate Division of the High Court with no written grounds of decision rendered.
The Income Tax Act 1947 - Income Tax (International Tax Compliance Agreements) (Crypto‑Asset Reporting Framework) Regulations 2026 (CARF Regulations) was gazetted on 11 August 2026 and come into operation on 1 January 2027. The CARF Regulations incorporate the requirements of the CARF into Singapore’s domestic legislative framework. The IRAS has also updated its webpage “CARF Overview and Latest Developments” and published the e-Tax Guide “Crypto-Asset Reporting Framework (First Edition)” on 11 August 2026.
The Income Tax Act 1947 - Income Tax (International Tax Compliance Agreements) (Common Reporting Standard) (Amendment) Regulations 2026 has been gazetted on 11 August 2026. The IRAS has also updated its webpage “CRS Overview and Latest Developments” and the e-Tax Guide “Common Reporting Standard (Fifth Edition)” to incorporate the amended CRS requirements.
The Income Tax Act 1947 - Income Tax (International Tax Compliance Agreements) (United States of America) (Amendment) Regulations 2026 has been gazetted on 11 August 2026.
On 31 July 2026, the Monetary Authority of Singapore issued a circular FDD Cir 05/2026 titled Fund Tax Incentive Schemes, providing updates to the fund tax incentive schemes under sections 13D, 13O, 13OA and 13U of the Income Tax Act 1947. This tax bulletin summarises the key updates to the fund tax incentive schemes set out in the circular.
On 7 August 2026, IRAS updated its “Real Estate” webpage with the GST treatment and input tax implications of the option to purchase with a nominee clause.
The Inland Revenue Authority of Singapore (IRAS) published the eleventh edition of its e-Tax Guide 'GST: Guide for Property Owners and Property Holding Companies' to update the GST treatment and input tax implications of the option to purchase with a nominee clause in paragraphs 7.11 to 7.15 and 9.10 to 9.13.
On 6 August 2026, IRAS updated its webpage with the payment mode for search and document fees.
The Inland Revenue Authority of Singapore (IRAS) published the eighteenth edition of its e-Tax Guide 'GST: Major Exporter Scheme' to include the contact details of air express companies (AECs) in Appendix F.
On 3 August 2026, IRAS updated its Corporate Income Tax Filing Season 2026 with myTax Portal Troubleshooting Assistant (Corporate Tax). Taxpayers may now receive step-by-step troubleshooting guidance for common myTax Portal login and access issues.
On 3 August 2026, the IRAS published a summary of a ruling on whether the tax deferred distributions derived from a foreign trust would be subject to Singapore income tax.
On 3 August 2026, the IRAS published a summary of a ruling on whether the gain from the sale of the properties is capital in nature and not subject to tax under the Income Tax Act 1947.
On 31 July 2026, IRAS updated its webpage for Form IR8A, Appendix 8A and Appendix 8B for YA 2027.
On 30 July 2026, IRAS updated its ‘Life Insurance Relief” webpage to reflect that, from 2026, life insurance relief is expanded to cover insurance premiums paid by wives on their husbands’ life insurance policies.
On 30 July 2026, IRAS updated its “Spouse Relief/Spouse Relief (Disability)” webpage to reflect that, from YA 2026, both reliefs extend to maintenance payments made by legally separated wives to their husbands under a court order or deed of separation.
On 29 July 2026, the Government introduced the SME Cash Grant 2026 to support businesses facing higher energy and operating costs arising from the Middle East situation.
All ACRA-registered companies, sole proprietorships and partnerships will be assessed for eligibility automatically, with no application required. Businesses with local qualifying employees will receive S$500 per employee, based on the highest monthly headcount from April to June 2026, capped at S$2,500 per business, subject to timely CPF contributions. Sole proprietorships and partnerships without local qualifying employees may receive a flat S$500 grant if at least one local owner has YA 2025 net trade income of no more than S$100,000.
The grant will be paid in November 2026 via GIRO or PayNow Corporate and is taxable.
On 28 July 2026, the IRAS updated its guidance on ABSD remission timeline extensions for qualifying complex residential projects to support licensed housing developers undertaking large scale en-bloc redevelopments. For land acquired from 29 July 2026, qualifying large en-bloc sites may receive up to six years, and mega sites up to seven years, to complete and sell units, with an additional six months for projects meeting more than one qualifying category. Mega sites must also sell at least 50% of units within six years from the acquisition date to avoid ABSD clawback.
IRAS updates its webpage 'Applying for a Certificate of Residence/ Tax Reclaim Form' on 27 July 2026 to provide clearer guidance on the conditions that foreign-owned investment holding companies must meet to substantiate that they have valid reasons for setting up operations in Singapore.
IRAS updated its webpage to add Greenland to the list of jurisdictions that have exchange relationships with Singapore.
IRAS updated its webpage to clarify the following:
- Related party individuals such as shareholders or directors who fall within the definition of “related party” under Section 2 of the Income Tax Act 1947.
- The value of Related Party Transactions (“RPT”) for reporting in the RPT Form excludes director fees.
IRAS has enhanced its webpage for readability and included the following standard sections for each of the areas of audit:
- What you should do
- Consequences of involvement/errors
IRAS has updated its webpages ‘Basic guide for partnerships’ [https://www.iras.gov.sg/taxes/individual-income-tax/self-employed-and-partnerships/tax-obligations-of-partnerships/basic-guide-for-partnerships] to highlight that e-Filing of Form P will be compulsory from YA2027. The webpage ‘Responsibilities of precedent partners' is also updated accordingly and to inform that the Partnership Allocation Template must be completed for partnerships with more than 10 partners.
IRAS has enhanced its webpage for readability and included a new section on common fringe benefits such as:
- Accommodation and related household benefits
- Transport and related benefits
- Meals and gifts
- Clothing, accessories and personal grooming benefits.
The IRAS webpage has been reworded to provide greater clarity in relation to payments for technical services and management services under sections 12(7)(b) and (c) of the Income Tax Act 1947 respectively.
IRAS published a taxBytes@IRAS article highlighting that a range of support measures are offered by the IRAS and IMDA. Applications for the GST InvoiceNow Transition Grants and the InvoiceNow Queen Bee Grant opened on 1 July 2026. Free-of-charge Solution Packages are also available for SMEs until March 2031.
IRAS has updated the explanatory notes to include explanations and information on its recommended record keeping requirements and standard template for tracking of the foreign income.
In his Parliamentary Reply, Senior Minister of State for Finance, Mr Jeffrey Siow shared that from 2021 to 2025, IRAS invoked its anti-avoidance powers on 124 occasions and assessed $49 million in additional tax, of which $48 million has been recovered to-date. All but one of the cases involved taxpayers extracting profits as tax-exempt dividends or interest-free shareholder loans.
In response to another question on WMCR, he announced that, based on Year of Assessment 2025 data, about 9,500 working mothers claimed a lower amount of WMCR under the fixed-dollar basis than they would have under the previous percentage-based basis, for children born or adopted on or after 1 January 2024. The difference in tax paid by these working mothers is about $7.5 million in total, or about $800 per person on average.
The Monetary Authority of Singapore (MAS) is seeking feedback on a proposed legislative framework introducing a new Protected Cell Company (PCC) structure. The consultation ends on 7 August 2026.
The proposed PCC structure comprises a central ‘Core’ and separate ‘Cells’ within a single legal entity, the assets and liabilities of which are legally segregated, allowing multiple insurance solutions to be independently managed within a single PCC, with the Core providing centralised governance and oversight.
The MAS has identified the following insurance use cases for the proposed PCC structure: captive insurance, insurance-linked securities, and sovereign risk pools.
For income tax purposes, the MAS has proposed that the chargeable income of each cell be aggregated to be taxed at the PCC level. At the same time, an individual cell’s unabsorbed allowances, losses and donations remain ring-fenced, GST applies at the cell level, and similarly each cell will be treated as a separate person for stamp duty purposes. In providing feedback, industry participants may want to seek clarity on issues such as the Core’s standalone tax position, incentive eligibility, allocation of common tax items, GST on intra-PCC supplies, and the tax treatment of re-domiciliation and availability of stamp duty relief on transfers of assets between cells.
The Goods and Services Tax Act 1993 - Goods and Services Tax (General) (Amendment No. 2) Regulations 2026 has been published on 6 July 2026 to include “the International Passenger Terminal at Singapore Cruise Centre (HarbourFront)” in the definition of “cruise terminal”.
The Income Tax Act 1947 - Income Tax (Exemption of Income of Foreign Trusts) (Amendment) Regulations 2026 has been gazetted on 6 July 2026.
IRAS published a taxBytes@IRAS article ‘Flower Garland Sales in Nightclubs: What These Businesses Must Get Right for Tax’ explaining the tax treatment of flower garland sales and highlighting the records and arrangements that businesses should get right to avoid incorrect GST treatment, under-reporting income or missed withholding tax obligations.
The Revised Edition of the Laws (Section 17(2)) Order 2026 was published on 2 July 2026. It states that the 2026 Revised Edition of the subsidiary legislation set out in the Schedule, including the following GST subsidiary legislation, comes into force on 3 July 2026:
- Goods and Services Tax (Application of Customs Act 1960) (Provisions on Trials, Proceedings, Offences and Penalties) Order 1994
- Goods and Services Tax (Application of Legislation relating to Customs and Excise Duties) Order 1994
- Goods and Services Tax (Bail and Personal Bond) Regulations 2019
- Goods and Services Tax (Buildings, Flats and Tenements for Residential Purposes) Order 2010
- Goods and Services Tax (Composition of Offences) Regulations 1993
- Goods and Services Tax (Electronic Service) Regulations 2019
- Goods and Services Tax (Excluded Transactions) Order 1994
- Goods and Services Tax (General) Regulations 1993
- Goods and Services Tax (Imports Relief) Order 1994
- Goods and Services Tax (International Arrangements Relief) Notification 1994
- Goods and Services Tax (International Services) Order 1993
- Goods and Services Tax (Mode of Payment for Refunds) Regulations 2021
- Goods and Services Tax (Prescribed Information) Order 2004
- Goods and Services Tax Voucher Fund Regulations 2014
- Goods and Services Tax Voucher Fund (Composition of Offences) Regulations 2014
On 1 July 2026, the IRAS published a summary of a ruling on whether dividend income from Company B that is used for the payment of one-tier tax exempt dividends by Company A to its shareholder is regarded as received or deemed to be received in Singapore under Section 10(25) of the Income Tax Act 1947.
On 1 July 2026, the IRAS published summaries of two advance rulings related to whether the companies meet economic substance requirement under Section 10L of the Income Tax Act 1947 (ITA) and therefore qualify as an “excluded entity” for the purpose of Section 10L of the ITA.
Advanced Ruling Summary No. 9/2026 Advance Ruling Summary No. 11/2026
International updates
Following the Government’s enhanced proposal released in May 2026 in response to feedback received during the public consultation, the Inland Revenue (Amendment) (Tax Deductions for Intellectual Property Expenditure) Bill 2026 (Bill) was gazetted on 16 October 2026. The Bill largely reflects the enhanced proposal and seeks to enhance the profits tax deductions available for capital expenditure incurred in acquiring or licensing eligible intellectual property (IP) rights.
The OECD has published version 2.0 of the GloBE Information Return (GIR) XML Schema and accompanying User Guide which will apply from 25 June 2028 to all exchanges, including those relating to amendments and corrections of previously exchanged GIR information.
The GIR XML Schema and User Guide has been updated to reflect 2026 revisions to the GIR following the adoption of the Side-by-Side Package by the OECD/G20 Inclusive Framework on BEPS, as well as a number of technical improvements.
The OECD has published the ninth peer review of BEPS Action 13 minimum standard on Country-by-Country Reporting (CbCR). The review assesses how jurisdictions are implementing the CbCR minimum standard as of April 2026 and highlights continued progress in strengthening tax transparency.
The Central Government, vide a notification dated 13 October 2026, has made effective the provisions of the protocol signed in 2024 (Protocol 2024) amending the Double Tax Avoidance Agreement (DTAA) between India and Mauritius. Accordingly, the protocol, signed on 7 March 2024, came into force on 10 August 2026 after both countries completed their domestic ratification procedures.
The Protocol 2024 introduced two important anti-tax-avoidance measures by replacing the preamble to the India-Mauritius DTAA and introducing Article 27B ‘Entitlement to Benefits’ i.e., the principal purpose test (PPT) which will deny DTAA benefits if one of the principal purposes of an arrangement was to obtain a tax benefit under the DTAA which is not consistent with the object and purpose of the DTAA.
Tax developments, regulatory updates and practical insights for foreign investors in Korea. Featured Insight in this edition ‘When Business Expenses Become Entertainment Expenses: A Korean Tax Risk Many Foreign-Invested Companies Overlook’.
Tax news
- National Tax Service Holds 2026 Tax Administration Reform Committee Meeting
- Government Promulgates Amendments to the Presidential Decrees of Four Tax Laws
- Ministry of SMEs and Startups and National Tax Service Provide Tax Administrative Support for 2,559 AI SMEs and Startups
- National Assembly Budget Office Highlights Key Issues in Virtual Asset Income Taxation
Changes in tax laws
- Amended Presidential Decree of the Corporate Income Tax Law
- Amended Presidential Decree of the Individual Income Tax Law
- Amended Presidential Decree of the Comprehensive Real Estate Holding Tax Law
- Amended Presidential Decree of the Local Tax Law
- Amended Presidential Decree of the Individual Consumption Tax Act
- Amended Presidential Decree of the Transportation, Energy and Environment Tax Act
- Amended Presidential Decree of the Inheritance and Gift Tax Law
Rulings update
- Recapture of Acquisition Tax and Property Tax Relief Where an Industrial Building Is Demolished Within Two Years and Rebuilt for the Same Use
- Input VAT Deductibility for Passenger Vehicles Purchased by an Imported Vehicle Dealer for Use as Loaner Vehicles".
The OECD Secretary-General Tax Report to the G20, published on 15 October 2026, provides an update on developments in the OECD’s tax work since April, with a focus on the role tax policy can play in supporting business dynamism and economic growth.
The report includes an annexed analysis ‘Enhancing Corporate Tax Systems to Support Business Dynamism’ which draws on ongoing OECD research to explore how corporate income tax (CIT) policy can help create a more dynamic and productive business environment. It highlights the role of effective CIT design in encouraging investment, innovation and growth, while underscoring the need for a broader policy framework that addresses structural constraints to business development.
The 2026–27 Federal Budget included a number of high-profile tax measures. However, some of the less prominent measures may also have practical implications for businesses, particularly those companies experiencing a temporary downturn or for small business who invest in business assets.
Two measures that businesses should have on their radar are the reintroduction of loss carry back for companies and the permanent $20,000 instant asset write-off for small business. Both measures are law and broadly apply from 1 July 2026 and may have implications for cash flow, dividend and investment decisions.
On 14 October 2026, the European Parliament released a preliminary report on the EU's DAC recast. The report proposes removing the DAC6 reporting carve-out for groups within the scope of the Pillar Two Directive, citing limited experience with how the rules interact. It also proposes deleting the proposed anti-gold-plating provision. Economic and Financial Affairs Committee amendments are due 12 November 2026, with a committee vote planned for 14 January 2027 and a plenary vote expected in February 2027.
OECD blog ‘Supporting low earners while making work pay: Can tax systems do both?’ examines how taxes, benefits and tax reliefs interact across income levels and highlights approaches to support low earners while incentivising increasing earnings.
An OECD blog ‘From spare rooms to second-hand sales: How tax reporting continues to adapt to the platform economy’ which explores how the OECD’s Model Reporting Rules for Digital Platforms support tax transparency while helping maintain a level playing field for platform-based economic activity.
OECD Pillar Two implementation continues to advance around the world. Cyprus has submitted draft legislation to align its domestic minimum top‑up tax with EU Directive 2022/2523, limiting the current regime to financial years beginning on or after 31 December 2024 and before 31 December 2025 and introducing a qualified domestic minimum top‑up tax from financial years beginning on or after 31 December 2025.
In its budget 2027 proposal published on 7 October 2026, Norway proposes adopting the side‑by‑side package, including simplified ETR, substance‑based incentive and ultimate parent entity safe harbours, and extending the transitional country‑by‑country reporting safe harbour to financial years starting no later than 31 December 2027, with amendments effective for financial years starting after 31 December 2025; May guidance would also extend the transitional UTPR safe harbour to accommodate 53‑week years.
Luxembourg’s draft 2027 state budget triples the 2026 Pillar Two revenue estimate to €240 million and projects €200 million for 2027, within total central government revenue of €31.8 billion.
Thailand has opened a public consultation on principles for qualified refundable tax credits that are usable against tax, with any excess refundable within four years; consultation closes 5 November 2026.
This episode of OECD Behind the Numbers podcast explains what the tax wedge tells us about wages, the choices couples and families make about work, and household budgets.
Welcome to our Tax in Motion Budget Edition which brings you the key tax proposals of Budget 2027 based on the Budget speech as announced by the Prime Minister and Finance Minister on 9 October 2026.
Highlights include:
- Lower tax rates and higher capital allowances for Micro, Small and Medium Enterprises: Reduced tax costs and greater capital allowances to support business investment.
- Enhanced Global Services Hub and family-office incentives: More competitive incentives to strengthen Malaysia’s position as a regional business and wealth-management hub.
- Enhanced green investment incentives: Broader coverage and longer-term certainty to encourage investment in green technologies and renewable energy.
The 57th Goods and Services Tax (GST) Council meeting was held on 8 October 2026 and chaired by the Union Finance and Corporate Affairs Minister Nirmala Sitharama. The meeting was held after over a year as a continuation to the overhaul in GST 2.0, undertaken at the 56th GST Council meeting which was held in September 2025. Several key clarifications and process reforms were proposed at the 57th council meeting, which are summarised in this Tax Insights.
The Delhi bench of the Income-tax Appellate Tribunal (Tribunal) concluded that gains derived by an Irish tax resident from transferring its ownership interest in a US entity (which holds an Indian entity) to another group entity as part of a global internal restructuring were not taxable in India under the India–Ireland Double Taxation Avoidance Agreement (DTAA). Since the interest transferred was in a US resident entity, Article 13(5) of the India-Ireland DTAA did not apply. The gains were covered by Article 13(6) of the India-Ireland DTAA and taxable only in Ireland. The Tribunal also concluded that receipts from the sale of standard software and related support were not taxable in India as royalty or fees for technical services.
This issue covers:
- Tax Incentives - Amendments to the Industrial Innovation Statute passed third reading to enhance corporate talent retention and support startup development.
- Value-added Tax - Ministry of Finance clarifies that sales of virtual assets and stablecoins defined under the Virtual Asset Service Act are outside the scope of business tax.
The Australian Taxation Office (ATO) has released updated guidance on how the extended definition of “employee” for Superannuation Guarantee purposes applies to payments made to certain contractors, significantly expanding on prior ATO guidance.
This issue provides an overview of the guidelines on the imposition of stamp duty on service agreements, updated guidelines on capital gains tax for unlisted shares, updated guidelines on capital gains tax for foreign capital assets, and many more.
On 14 September 2026, the Ministry of Finance issued Circular No. 136/2026, effective from 15 September. It amends the existing rules by revising the documents required when goods produced, processed or outsourced for processing are sold or entrusted to another business entity for export and treated as not subject to Special Sales Tax.
This issue includes:
- Pre-election Economic and Fiscal Update released
- Election campaigns get underway where the notable contrasts on each major party’s tax policies are highlighted. Christopher Luxon repeatedly emphasised National's commitment to no new taxes in his speech while Chris Hipkins reiterated the trade-offs of Labour's targeted capital gains tax policy.
Following the 2026/2027 Budget and the legislative proposal released earlier this year, the Stamp Duty (Amendment) (No. 3) Bill 2026 (Bill) was gazetted on 2 October 2026. The Bill seeks to enhance stamp duty relief for intra-group transfers (section 45 relief) through two key measures:
- Expanding the scope of associated bodies corporate through a new association test based on beneficial interest or voting rights; and
- Lowering the association threshold from 90% to 75%.
Following the 2026 Policy Address announced in September 2026, the Government has recently set out in a paper submitted to the Legislative Council Panel on Financial Affairs more details of the proposed concessionary tax regime under the preferential policy package to attract strategic industries and investments.
Uruguay published Decree 206/026 in the Official Gazette on September 8, 2026. This decree repeals Decree 325/025, which established the conditions under which Uruguayan constituent entities of Multinational Enterprise (MNE) Groups covered by a tax stability clause in force when the Domestic Minimum Top-up Tax (DMTT) entered into effect, could qualify for a (full or partial) exemption from the tax.
Romania has deposited its instrument of ratification for the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (the STTR Convention). The STTR Convention will enter into force for Romania on 1 February 2027.
Malaysia signed the Multilateral Competent Authority Agreement on the Exchange of GLOBE Information on 16 July 2026, according to an OECD update published 1 October 2026.
This TP In Brief highlights recent transfer pricing developments in Canada, South Africa and Malaysia, as well as the latest UN discussions on the prevention and resolution of tax disputes.
Panama enacted Law No. 526 of May 28, 2026, published in Official Gazette No. 30,534-B. The Law amends and adds articles to the Tax Code and creates an economic substance regime for certain foreign-source passive income earned by entities established or domiciled in Panama that belong to multinational groups. The Law was regulated by Executive Decree No. 32 of September 2, 2026, published in Official Gazette No. 30,603-B. The regime applies as of the 2027 fiscal period, that is, for fiscal years beginning on or after January 1, 2027.
Further to the Legal Alert 01/2025 on the Employee Welfare Fund (EWF), there has been a change to the effective date for collecting employee and employer contributions under the EWF. The EWF is a government-mandated fund introduced to improve employees’ welfare benefits and financial security. Under the latest update, the start date for collecting both employee and employer contributions has been postponed from 1 October 2025 to 1 October 2026. The application period for the contribution rates has also been adjusted.
For years, the Bureau of Internal Revenue (BIR) has steadily laid the groundwork for the country’s transition to electronic invoicing (e-invoicing), reflecting the government’s push toward a more efficient, transparent and data-driven tax system. What was once viewed as a future compliance requirement is now becoming an operational reality. With the issuance of Revenue Memorandum Circular (RMC) No. 98-2026, the BIR has moved beyond policy development toward active implementation. The circular sets out the guidelines and reiterates that covered taxpayers must comply by 31 December 2026.
This edition covers recent Australian tax changes and proposals, including Treasury exposure drafts for more Federal Budget reforms and the ATO’s latest findings reports, to help organisations assess impacts, align processes, and manage tax compliance.
International Tax News is designed to help multinational organisatons keep up with the constant flow of tax developments. Among the topics featured in this month's edition are:
- Australia - ATO finalises software royalty ruling and opens consultation on a new risk framework
- Singapore – Finance (Income Taxes) Bill published
- New Zealand – Proposed simplifications for Pillar Two compliance obligations
- Italian Supreme Court decision on beneficial ownership status
In a recent ruling, the Delhi bench of the Income-tax Appellate Tribunal (Tribunal) concluded that for constitution of a supervisory permanent establishment (PE) under the India-Japan Double Taxation Avoidance Agreement (DTAA), the duration threshold must be applied project-wise and not employee-wise and overlapping days cannot be counted more than once merely because several employees are present at the same time. Furthermore, the requirement that the supervisory activities be connected with a building site, construction, installation, or assembly project are cumulative with the duration test and mandatory.
The OECD just released the 11th edition of the full version of the Model Tax Convention on Income and on Capital, incorporating the changes agreed in November 2025, bringing greater clarity to remote working, offering guidance on how home-office arrangements should be treated under tax treaties, and providing much-needed certainty for businesses operating internationally.
The revised OECD Model also introduces key measures to better reflect today’s global economy. These include an optional provision on taxing extractive industries, improving consistency in approaches to ensure income from natural resource activities is taxed where extraction occurs.
More broadly, the amendments provide guidance that aims to facilitate consistency in treaty interpretation, helping to support cross-border trade and investment and promote greater certainty in international tax matters.
The German parliament has approved for ratification the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR-MCAA) on 25 September 2026, following Bundestag approval on 9 July 2026. Germany had signed the agreement on 19 September 2025. The GIR-MCAA facilitates the automatic exchange of GloBE Information Returns between participating jurisdictions, helping to reduce duplicate filing obligations for multinational group.
The House Ways and Means Committee on September 16 voted 38 to 5 to approve H.R. 10357, the Digital Asset Tax Certainty Act, as amended by a chairman’s substitute, with all Committee Republicans and 12 Committee Democrats supporting the bill. The bill consolidates and modifies a series of digital asset tax proposals developed over the course of 2026, including provisions considered at the Committee's June legislative hearing (June package).
On 23 August 2026, the National Assembly passed Law 11, which amends the existing Law on Customs 54. The new law will take effect on 1 March 2027. To implement Law 11, the authorities have released the following draft guidance documents for public consultation:
- A draft Decree replacing Decree 08 and Decree 167; and
- A draft Circular replacing Circular 38, as amended by Circulars 39 and 121
In a significant decision, the Punjab and Haryana High Court declared the insertion of section 147A of the Income-tax Act, 1961, introduced vide the Finance Act, 2026 retrospectively with effect from 1 April 2021, to be unconstitutional.
This issue includes: September tax Bill has been released: The latest tax bill, Taxation (Annual Rates for 2026–27, FBT Simplification, Foreign Investment Funds, and Remedial Measures) Bill (the Bill) was introduced to Parliament on 10 September 2026, alongside commentary from Inland Revenue. The Bill provides legislative design around several Budget 2026 items and brings together a broad package of simplification, integrity and remedial changes across the tax system. The Bill is significantly larger than other recent annual rates bills and covers a breadth of tax matters.
Treasury has released draft materials setting out the first stage of the Government's reforms to better target the Research and Development (R&D) Tax Incentive. The measures form part of the tax reform package announced in the 2026-27 Budget and respond to recommendations of the Ambitious Australia - Strategic Examination of Research and Development report published by the Department of Industry, Science and Resources in March 2026.
The Mumbai bench of the Income-tax Appellate Tribunal (Tribunal) upheld the deletion of a demand on account of non-deduction of tax on year-end provisions. The Tribunal concluded that the year-end provisions recognising estimated expenditure for the relevant financial year, in the absence of crystallised liability and identifiable payees, does not give rise to an obligation to deduct tax at source (TDS). Furthermore, the Tribunal also reaffirmed that the taxpayer cannot be treated as in default under section 201 of the Income-tax Act, 1961 (the Act) for non-deduction of tax at source, as the relevant expenditure has already been disallowed under section 40(a)(i) or (ia) of the Act.
With Pillar Two filing deadlines fast approaching for 30 June taxpayers in Australia, make sure you know what needs to be done, by when, and how PwC can help.
Federal Court upholds Part IVA in Hilton, cancelling an AUD173m tax benefit from a pre-sale restructure and share sale of a Sydney hotel.
Tax news:
- Government finalizes 2026 tax reform bill
- Ministry of the Interior and Safety announces the government’s 2026 local tax reform proposals
- National Tax Service announces key initiatives of the tax administration plan for the second half of 2026
Changes in tax laws:
- Amended Basic National Tax Law
- Amended Customs Act
- Amended Presidential Decree of the Individual Consumption Tax Act
- Amended Presidential Decree of the Transportation, Energy and Environment Tax Act
- Amended Enforcement Rules of the Customs Act
Rulings update:
- VAT treatment of employee discount included in taxable income for corporate income tax purposes
The OECD held a signing ceremony of the STTR MLI, marking the first concrete step towards the implementation of the STTR in bilateral tax treaties and enabling developing countries to protect their domestic tax base. The first signing ceremony of the STTR MLI marked a major milestone in the work of the OECD/G20 Inclusive Framework on BEPS as it delivers upon its objective of reforming international tax rules to deliver a stronger, fairer, global tax system.
The OECD/G20 Inclusive Framework (IF) on 11 September 2026 released a package of Pillar Two materials, including a revised GloBE Information Return (GIR), a framework for the full legislative review of jurisdictions’ Pillar Two rules, and Administrative Guidance on certain conditional taxes and issues with respect to Qualified Domestic Minimum Top-up Taxes (QDMTT) fiscal-period mismatches.
The revised GIR implements reporting changes arising from the January 2026 Side-by-Side (SbS) Package. For qualifying US-parented groups applying the SbS safe harbour, certain Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR) reporting is reduced, although QDMTT reporting generally remains. Following the IF release, US Treasury separately welcomed the revised GIR.
Following the Supreme Court’s remit in 2023, the Karnataka High Court has now pronounced its judgement in a batch of appeals involving several transfer pricing (TP) issues.
This TP In Brief highlights three recent US transfer pricing case law developments involving periodic adjustments under a cost-sharing arrangement, stock-based compensation under the cost-sharing regulations, and the conclusion of litigation involving Section 482's blocked-income rules.
The report compares tax reforms introduced or announced in 2025 across 92 jurisdictions. It assesses the various approaches countries are taking to sustainably finance public services, social protection, investment and other spending needs in a context of slow growth and rising public debt.
On 4 September 2026, the Australian Taxation Office published its long-awaited final view on when cross-border payments made by software distributors are royalties in Taxation Ruling TR 2026/2. At the same time, the ATO released draft Practical Compliance Guideline PCG 2026/D4, which sets out a five-zone risk framework that taxpayers are expected to use to self-assess their royalty withholding tax risk. The draft PCG is open for an initial period of consultation until 2 October 2026 and introduces an entirely new ‘residual risk assessment calculation’ to test apportionment concepts.
Treasury has released for consultation a package of exposure draft law and explanatory materials that aims to give effect to the Government's 2026-27 Budget announcement that a 30% minimum tax will apply to the income of discretionary trusts. The draft law confirms the start date of 1 July 2028 and, importantly, sets out the detail of two ways in which affected trusts can respond - a three-year rollover to restructure out of the discretionary trust, or an election to remain outside of the minimum tax regime by locking in the trust’s nominated beneficiaries and their distribution proportions indefinitely.
The Delhi bench of the Income-tax Appellate Tribunal (Tribunal), in a recent ruling, concluded that the deputation of expatriate employees by a Korean enterprise to its Indian subsidiary did not, by itself, constitute a permanent establishment (PE) in India.
The Tribunal concluded that the conditions for a fixed-place PE under Article 5 of the India-Korea Double Taxation Avoidance Agreement were not satisfied, as the Revenue failed to establish that the taxpayer carried on its business wholly or partly through a fixed place in India.
China has ended the long-standing exemption for dividends and bonuses paid by foreign-invested enterprises to foreign individuals, and such income is now subject to 20 percent individual income tax with effect from 1 September 2026. Foreign-invested enterprises must withhold the tax on payment and declare and pay it by the 15th day of the following month, while recipients remain liable if withholding is not made.
This TP In Brief addresses key themes from recent stakeholder comments on the OECD’s proposed revisions to Chapter VII of the OECD Transfer Pricing Guidelines on intra-group services.
International Tax News is designed to help multinational organisations keep up with the constant flow of tax developments. Among the topics featured in this month's edition are:
- US Treasury and IRS issue four OBBBA international tax proposed regulation packages
- Poland's Draft Act on the Polish Digital Service Tax
- Hong Kong - Consultation on enhancing Corporate Treasury Centre tax concession launched
- Updated Dutch policy Decree on ATAD II – Helpful clarifications for taxpayers
Integrated Circuit (IC) and Industrial Mother Machine (IMM) enterprises frequently engage in cross-entity transactions in their daily operations and technology iterations, including contributing non-monetary assets such as specialized equipment and patented technologies as equity investments, asset exchanges, or production line replacements and integrations. Under the current tax policies, enterprises making non-monetary asset investments may enjoy a 5-year instalment payment of tax pursuant to Caishui [2014] No. 116; enterprises investing with technological achievements may elect to defer taxation until the transfer of equity pursuant to Caishui [2016] No. 101; and if asset or equity transactions meet the conditions for special tax treatment under Caishui [2009] No. 59 or Caishui [2014] No. 109, the corresponding deferral treatment may apply. Beyond these, for non-monetary asset exchanges between enterprises involving fixed assets, intangible assets, or equity that do not qualify for the aforementioned tax incentives, the transactions shall be deemed as sales of goods or transfers of properties under the Corporate Income Tax (CIT) Law, and the transfer income shall be recognized and CIT paid at once in the same period when the transaction occurs.
On 28 August 2026, the Ministry of Finance (MOF), the State Taxation Administration (STA) and the China Securities Regulatory Commission (CSRC) jointly issued the “Public Notice on Regulating the Individual Income Tax (IIT) Policy on the Transfer of Restricted Shares of Listed Companies”1 (Public Notice of MOF, STA and CSRC [2026] No. 26, hereinafter referred to as "PN No. 26") to refine the IIT policies and administration requirements for the transfer of restricted shares of listed companies and unify the IIT rules across capital market segments. PN No. 26 took effect on the same day.
On 23 July, the Government issued Decree 296/2026/ND-CP, amending the existing enterprise registration regulations, including requirements for identifying and declaring UBOs. Earlier, on 21 July, the Government issued Decree 288/2026/ND-CP, introducing administrative penalties for non-compliance with these UBO declaration and reporting requirements. Both decrees took effect on their issuance dates.
This edition covers recent Australian tax changes and proposals, including Treasury exposure drafts for the next tranche of negative gearing and CGT reforms, and final rulings on Payday Super, to help organisations assess impacts, align processes, and manage tax compliance.
On 12 May 2026, the Ministry of Finance amended the “Guidelines for Tax Authorities on Documentary Review of Profit-Seeking Enterprise on Disaster Loss Reports and Claims for Scrapping of Inventories or Fixed Assets”.
This issue includes:
- Determining chargeable income from a limited liability partnership’s (LLP) profits
- Extension of foreign-sourced income exemption
- Further 50% tax deduction for employers providing additional caregiving leave benefit
- Income tax deduction for contributions to anti-corruption education and prevention programmes
- Guidelines on Capital Gains Tax Exemption for Disposals of Shares for Initial Public Offering Purposes
- Guidelines on incentive claims for upstream petroleum
- Updated FAQs on Global Minimum Tax
Treasury and the IRS on August 26 published proposed regulations implementing the One Big Beautiful Bill Act (OBBBA) changes to the controlled foreign corporation (CFC) pro rata share rules under Sections 951 and 951A. Most significantly, the proposal would allocate subpart F income, tested income, and tested loss based on the period during which a US shareholder directly or indirectly owns CFC stock, generally using daily proration, rather than limiting Section 951(a)(1)(A) inclusions to shareholders that own stock on the last day of the tax year of the foreign corporation on which it was a CFC (the last relevant day).
The proposal also would require a CFC tax year to close when the corporation becomes or ceases to be a CFC and would permit an elective closing for certain significant ownership shifts exceeding 50 percentage points. It also addresses transition-period dividends, related Form 5471 reporting, midyear stock issuances and redemptions, and the phaseout of the Reg. 1.245A-5 extraordinary reduction rules for later CFC tax years.
The Mumbai bench of the Income-tax Appellate Tribunal (Tribunal) examined whether the trademark licence fees paid by an Indian company to its foreign group entity for use of a trademark constituted capital or revenue expenditure under section 37(1) of the Income-tax Act, 1961 (the Act)1. The Revenue contended that the payment conferred an enduring benefit through long-term brand-building and commercial exploitation of the trademark, resulting in the creation of an intangible capital asset. However, the taxpayer contended that it was revenue expenditure as no ownership or proprietary rights were acquired in the trademark. Under the trademark licence agreement, ownership continued to remain with the foreign licensor, while the taxpayer was granted a non-exclusive right to use the trademark in consideration for an annual fee equal to 5% of its gross profits.
The Tribunal upheld the Commissioner of Income-tax (Appeals) order, stating that the trademark licence fee was allowable as revenue expenditure. It observed that the taxpayer was granted only a limited, non-exclusive and time-bound right to use the trademark, without acquiring any ownership or proprietary interest therein. The Tribunal also emphasised that the enduring benefit test cannot be applied mechanically, particularly in the context of rapidly evolving technology, where what is current today may soon become obsolete. Accordingly, the state-of-the-art technology of modern times cannot necessarily be regarded as permanent or enduring.
The Central Board of Direct Taxes (CBDT) has issued a Guidance Note (Guidance Note) and Frequently Asked Questions (FAQs)1 on the Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS) to update and consolidate India’s framework for automatic exchange of financial account information. The Guidance Note replaces and builds on the earlier Guidance Note on FATCA and CRS dated 30 November 2016 (2016 Guidance) by aligning the regime with the Income-tax Act, 2025 (2025 Act); Income-tax Rules, 2026 (2026 Rules); and the global CRS framework of the Organisation for Economic Co-operation and Development (OECD) updated in 2025 (CRS 2025). It also reflects newer developments, such as specified electronic money products; central bank digital currencies; relevant crypto assets; enhanced reporting requirements under Form 166; and stronger expectations around data quality, Tax Identification Number reporting and compliance monitoring.
PwC New Zealand’s latest Tax Policy Bulletin includes a tax package targeting small businesses and a Revenue Alert calling out what the Inland Revenue describes as practices which result in tax not being correctly accounted for, as well as coverage of the usual publications and consultation items.
The continued uncertainty surrounding US trade policy has increased the importance of customs considerations in transfer pricing adjustments. As companies evaluate strategies to address the impact of US tariffs, post-importation transfer pricing adjustments have become an area of heightened focus because they could affect the customs value of imported goods and related tariff obligations.
Treasury and the IRS on August 20 published proposed regulations under Section 250 addressing the scope of the new exclusion from deduction eligible income (DEI) for certain property dispositions. Section 250(b)(3)(A)(i)(VII), as amended, excludes from DEI income and gain from sales or other dispositions of intangible property and any other property of a type that is subject to depreciation, amortization, or depletion by the seller. The proposed regulations are largely consistent with Notice 2025-78, issued in December 2025, which addressed similar issues, while adding definitions, examples, and anti-abuse rules. The proposed regulations also clarify that FDDEI is a subset of DEI and thus cannot exceed DEI.
From 1 July 2027 the 50% CGT discount for Australian resident individuals and trusts is replaced with cost base indexation, a 30% minimum tax on capital gains is introduced, and all pre-CGT assets (including those held by companies) are brought into the CGT regime. To transition to the new rules, CGT assets held at the end of 30 June 2027 are generally deemed to be sold just before 1 July 2027 and reacquired on 1 July 2027 at their market value (or at a value worked out under an apportioning method).
The Government of Maharashtra has issued operational guidelines on 19 August 2026 to implement the Maharashtra Global Capability Centre (GCC) Policy, 2025 announced on 3 November 2025. The operational guidelines translate the policy framework into a detailed procedure for application, approval and incentive claims, and appoint the Commissionerate of Services of the Maharashtra State, as the implementing agency.
The operational guidelines are relevant for multinational groups and Indian global companies that are establishing or expanding captive centres in Maharashtra. These guidelines specify various aspects such as the investment cut-off date, distinguish between new and expansion units, prescribe the process for obtaining the Letter of Intent, Registration Certificate and Incentive Eligibility Letter and introduce timelines for claim filing, continuing compliance, monitoring, recovery and grievance redressal.
The Delhi High Court has upheld a ruling by the Customs Authority for Advance Rulings (CAAR) that companies cannot claim customs duty exemption on goods moved from a Free Trade and Warehousing Zone (FTWZ) back into India’s Domestic Tariff Area (DTA) as a “re-import” where the original import transaction had already been completed. The case involved oil and gas contractors seeking to store equipment in an FTWZ after completing one project and later bring the same equipment back for use under a new project while claiming re-import benefits. The Court ruled that such movements constitute a fresh import rather than a re-import, emphasizing that the same transaction cannot be assigned different legal characters to obtain multiple tax concessions. The judgment also clarified that FTWZ provisions cannot be used to create additional fiscal benefits..
Business at OECD (BIAC) has published comments in response to the OECD’s public consultation on proposed targeted amendments to the Model Reporting Rules for Digital Platforms.
On 7 August 2026, the Customs Department issued Official Letter no. 20010/CHQ-GSQL in response to inquiries raised by Regional Customs Branch IV regarding the application of tax policies to export processing enterprises ("EPEs") that no longer satisfy one or more customs inspection and supervision requirements applicable to non-tariff zones.
Following the enactment of the 2026 tax reform, the “Special Documentation Retention Rules for Related Party Transactions” (the "Special Rules") were introduced. The amended Ordinance for Enforcement of the Corporation Tax Act was promulgated on 31 March 2026, and the NTA issued revisions to the Corporation Tax Basic Circular together with the NTA’s Administrative Guidelines on 30 June 2026, clarifying the requirements and the NTA’s approach to the administration.
The UN Intergovernmental Negotiating Committee completed its fifth substantive negotiating session (INC-5) on 13 August 2026. For the first time, delegates negotiated from complete drafts of the Framework Convention on International Tax Cooperation and two early protocols on cross-border services taxation and dispute prevention and resolution. Major differences remain over taxing rights, the treatment of existing tax treaties, and how much flexibility countries should have when joining the protocols. Revised drafts are expected ahead of the next negotiating session in Nairobi in November.
Our May-July 2026 edition of the Asia Pacific Financial Services Tax Highlights showcases the latest developments and issues facing the industry in the region.
China’s State Taxation Administration recently issued “Public Notice Regarding the Administrative Issues concerning the Corporate Income Tax Treatment of Enterprise Restructuring” (Public Notice [2026] No. 13, hereinafter referred to as “PN 13”) and its official interpretation. Following Caishui [2009] No. 59 and other relevant tax circulars, PN 13 provides more detailed and clear regulations regarding the special tax treatment applicable to tax resident enterprise merger and demerger transactions.
The Ministry of Finance issued Circular 90/2026/TT-BTC dated 30 June 2026 on tax registration, effective from 1 July 2026. The new Circular provides guidance on tax registration matters under the new Law on Tax Administration, reflecting a direction towards tax administration that is increasingly driven by data, electronic identification, system connectivity and the management of digital business models.
On August 3, 2026, the Ministry of Finance and Economy (MOFE) released a comprehensive bill proposing amendments to various tax laws, with the aim of reforming corporate and international taxation in Korea. The proposals encompass a broad range of measures, including the incorporation of the OECD/G20 Inclusive Framework's Pillar Two Side-by-Side Package into Korea's domestic global minimum tax legislation, the allowance of foreign tax credits for tax paid under Qualified Domestic Minimum Top-up Tax (QDMTT) regimes, and reforms to the domestic treasury share taxation regime. In addition, the government has proposed to introduce a new tax credit for the domestic production of strategically important products and adopt preferential tax incentives to promote regional R&D and investment activities. The proposals also include a reduction in the effective tax rate threshold under the Controlled Foreign Company regime to align it with the minimum tax rate under the GloBE Rules.
On 27 July 2026, the Cabinet extended the reduced value-added tax (VAT) rate of 7% from 1 October 2026 until 30 September 2027.
Business at OECD (BIAC) has published comments in response to the OECD’s public consultation on proposed revisions to its transfer pricing guidelines for intragroup services.
Treasury and the IRS released, on July 31, 2026, proposed regulations under Sections 898(c) and 960(d)(4). The proposed regulations implement the One Big Beautiful Bill Act (OBBBA) transition from the one-month controlled foreign corporation (CFC) deferral year, prescribe how certain foreign taxes are allocated between the short first required tax year and the succeeding tax year, and apply the statutory 10% foreign tax credit disallowance to taxes associated with distributions of post-June 28, 2025, Section 951A previously taxed earnings and profits (PTEP). These proposed regulations largely adopt the frameworks introduced in Notices 2025-72 and 2025-77, but with some accommodations in response to comments.
The Inland Revenue Board of Malaysia has issued the Malaysia Transfer Pricing Guidelines on Controlled Financial Transactions: Intra-Group Loans dated 30 July 2026. The Guidelines supplement Chapter 9 of the Malaysia Transfer Pricing Guidelines 2024.
China is using AI, platform reporting, and data-sharing tools to strengthen tax administration and revenue collection. Businesses are watching a growing pipeline of tax policy changes, including implementation of the new VAT law and proposed anti-avoidance and tax enforcement measures.
International Tax News is designed to help multinational organisations keep up with the constant flow of tax developments. Among the topics featured in this month's edition are:
- Australia – Additional Pillar Two Rule Amendments
- Australia - Parliament receives foreign-resident CGT reform proposals
- Hong Kong bill strengthens CRS administrative framework
- Singapore tax avoidance cases
- European Commission publishes its first review report on the Foreign Subsidies Regulation
Ministry of Finance Released Tax Ruling Clarifying Withholding Tax Requirements for Interest Payments Made via Online Peer-to-Peer Lending Platforms.
This edition covers recent Australian tax changes and proposals, including foreign resident CGT reforms before Parliament, and consultations on the proposed 30% minimum tax for discretionary trusts and application of the Critical Minerals Production Tax Incentive, to help organisations assess impacts, align processes, and manage tax compliance.
On 24 July 2026, the Ministry of Finance (MOF) and the State Taxation Administration (STA) jointly issued the 'Public Notice on Matters related to Individual Income Tax (IIT) on Offshore Trusts' (Public Notice of MOF and STA [2026] No. 21, hereinafter referred to as 'PN No. 21'). On the same day, the STA issued the “Public Notice on Matters related to the Collection and Administration of Individual Income Tax on Offshore Trusts” (Public Notice of STA [2026] No.15, hereinafter referred to as 'PN No. 15') with administrative measures to PN No. 21. The aforementioned Public Notices clarify the IIT rules applicable throughout the entire lifecycle of offshore trusts, introduce corresponding anti-avoidance measures, and stipulate relevant administrative requirements, with the aim of strengthening the IIT administration of offshore trusts.
On 21 July 2026, the Government issued Decree 291/2026, amending Decree 125/2020 on administrative penalties relating to tax and invoices. Decree 291 took effect immediately upon issuance. Decree 291 introduces new penalties for failing to provide information requested by the Vietnamese tax authorities for tax information exchange purposes. The Country-by-Country Report (CbCR) is one of the tax documentation requirements that falls within the scope of tax information exchange. Accordingly, non-compliance with the relevant filing and notification obligations under the three-tiered transfer pricing documentation framework may be subject to the new penalty regime introduced under Decree 291.
The Central Board of Direct Taxes recently published the eighth Annual Report on the Indian Advance Pricing Agreement (APA) Programme (APA Report), capturing outcomes for the financial year (FY) 2025-26. Strengthened with the increasing support and confidence from the taxpayers, the momentum of India’s APA Programme continues to remain strong, with a total of 1035 APAs signed as of 31 March 2026.
Following the 2026/27 Budget and the release of the Action Plan to Promote the Development of Corporate Treasury Centres in Hong Kong in the first half of 2026, the Government recently launched a public consultation on the proposed enhancements to the tax concession regime for corporate treasury centres (CTCs).
The Monegasque government has submitted draft legislation to the National Council that would implement a qualified domestic minimum top-up tax (QDMTT) in line with the OECD’s Pillar 2 global minimum tax rules.
In July 2026, the Ministry of Finance (MOF), the General Administration of Customs (GAC), and the State Taxation Administration (STA) jointly issued the Public Notice Regarding Adjusting the Consumption Tax (CT) Policies for Certain Battery Products (Public Notice of MOF, GAC and STA [2026] No. 20). It specifies that from 1 September 2026, a phased increase to the CT rate for certain battery products and resumption of CT on the battery products that were previously exempted will be implemented. These adjustments mark the end of the era of widespread tax exemption for the Chinese battery industry, which lasted over a decade. Acting as a regulatory tool, the tax change will profoundly impact upstream and downstream enterprises in the industry chain.
The office of the United States Trade Representative (USTR) on July 23 announced action under Section 301 of the Trade Act of 1974 imposing additional tariffs of 10% or 12.5% on imports from 60 trading partners that account for approximately 99% of US imports. The applicable tariff rate depends on each trading partner’s approach to forced labor import restrictions. For instance, a 10% tariff applies to economies that have imposed, committed to impose and enforce, or partially implemented restrictions on imports made with forced labor. A 12.5% tariff applies to economies that have failed to adopt a forced labor import prohibition. The tariffs are subject to specified product exclusions and are intended to address the failure of these economies to impose and effectively enforce prohibitions on imports produced wholly or in part with forced labor.
In a recent ruling of the Mumbai bench of the Income-tax Appellate Tribunal (Tribunal), it was concluded that the advertisement, marketing and promotion (AMP) expenses are allowable as revenue expenditure in the year of incurrence instead of being amortised.
The taxpayer acquired an already operational streaming and gaming platform, and during the relevant year, incurred AMP expenses to promote and expand the platform, and enhance user engagement. The taxpayer claimed such expenditure as a revenue expenditure, but which the Revenue contested as capital in nature, arguing that it entails an enduring benefit. The Tribunal affirmed the taxpayer’s position and concluded the expenditure to be revenue in nature and not subject to amortisation under section 35D of the Income-tax Act 1961. It observed that the enduring benefit test is not conclusive where any expenditure facilitates efficient business operations without creating a capital asset.
China has introduced formal rules to tax transfers of assets into offshore trusts and the income of those trusts, underscoring a tougher stance on wealth concealment and tax evasion. Effective immediately, undistributed trust income will be taxed annually, any relevant gain may be subject to 20% personal income tax, and taxpayers have a 90 day window to report and pay previously unpaid offshore trust taxes without late payment penalties.
From 1 July 2026, Circular No. 94/2026/TT-BTC on compliance and risk management in tax administration takes effect. The Circular updates the framework for tax compliance and risk assessment, risk management tools and corresponding tax administration measures.
New public tax disclosures are becoming available across the United States, Australia, and the European Union, providing unprecedented visibility into where multinational companies pay tax. Companies will need to be prepared to explain their tax positions or risk others doing it for them.
Japan issued guidance on the filing and exchange of GloBE Information Returns (GIRs) to provide information on Japan’s currently activated filing relationships and its expected exchange process.
Italy clarified compliance consequences for late or inaccurate GIR filings, GIR notifications, and tax returns. Taxpayers may use the voluntary compliance procedure (ravvedimento operoso) to regularise late or inaccurate GIRs/notifications with penalties reduced in the initial years of the regime; tax returns filed within 90 days are treated as valid late returns and can access reduced penalties via voluntary compliance, while returns filed after 90 days are considered omitted and not eligible for such reductions. Inaccurate returns can be voluntarily corrected with reduced penalties; and no penalties apply in the first three fiscal years except for fraud or gross negligence. Finally, elections made in a late GIR, including the transitional CbC safe harbour, remain valid.
Luxembourg proposed legislative amendments to adopt the OECD side-by-side package, the ultimate parent entity safe harbour, substance-based tax incentive safe harbour and the simplified ETR safe harbour as well as extend the transitional CbCR safe harbour by one year, thus aligning its rules with recent OECD guidance.
Simplifying Pillar Two, a pause in new international tax reforms, and creating greater stability around regimes would provide governments and businesses the chance to take stock of, and improve, complex corporate tax systems.
PwC’s quarterly transfer pricing briefing helps multinational organizations keep up with the continuous flow of relevant tax and transfer pricing developments. Below is a summary of Tax Insights and News Alerts published by individual members of the PwC network covering the period 1 April to 30 June 2026.
This issue includes:
- e-Invoice Special Voluntary Disclosure Programme
- FAQs on Transfer Pricing Guidelines
- Revised Guidelines on Malaysia Digital Status
- MIDA guidelines for Supply Chain Resilience Initiative
- Extension of incentives for Tun Razak Exchange Marquee status companies
The European Commission has unveiled its long-awaited Tax Omnibus and DAC Recast proposals, promising real simplification while touching on core questions around anti-avoidance, revenue, and Pillar Two. Proposed changes span CFC rules, withholding tax, and DAC reporting, with negotiations now moving to the Council and Member States.
The OECD reported continued progress under the BEPS Action 5 minimum standard, with the Forum of Harmful Tax Practices applying its revised peer review methodology for the first time in May 2026. Of 13 regimes reviewed, seven were found to be ‘not harmful’ and six remain ‘under review’.
Since the start of the BEPS project, the OECD has reviewed 347 preferential tax regimes, with more than 40% already abolished or in the process of being phased out.
The European Commission has published a report on the implementation and enforcement of the Foreign Subsidies Regulations (FSR), setting out its first assessment of how the regime has operated since becoming applicable in 2023 and signalling that while it believes the FSR does not need structural changes, it may introduce targeted procedural refinements. This study is based, in part, upon a much longer FSR Review Study that also has been published and contains interesting insights on the first years of the FSR.
The Ministry of Finance has issued Circular 89/2026/TT-BTC (“Circular 89”) to provide guidance on the implementation of a number of articles of the Law and Decree on tax administration and Circular 95/2026/TT-BTC (“Circular 95”), providing guidance on the application of Vietnam’s Double Tax Treaties (“DTT”), Mutual Agreement Procedures (“MAP”) and Advance Pricing Agreements (“APAs”).
The Ministry of Finance has issued Circular No. 91/2026 to provide guidance on the implementation of the Law on Tax Administration 2025 and Decree No. 254/2026 relating to e-invoices and electronic documents. The Circular took effect on 1 July 2026.
On 30 June 2026, the Ministry of Finance issued Circular no. 86/2026/TT-BTC on tax administration for imported and exported goods, replacing Circular no. 06/2021/TT-BTC. Circular 86 took effect on 1 July 2026.
The OECD's latest assessment of Pillar Two points to lower-than-expected revenue gains, while the June 30 filing cycle highlighted the scale and complexity of compliance. Questions are increasing about whether the costs and administrative burden are worth it relative to the outcomes achieved.
As tariffs and trade restrictions become a permanent feature of the business landscape, companies are being forced to connect customs, tax, supply chains, and market strategy. Those taking an end-to-end approach are finding real value in trade planning.
The Delhi bench of the Income-tax Appellate Tribunal (Tribunal), in the case of the taxpayer, concluded that a court-approved capital reduction cannot be mechanically re-characterised as ‘buyback’ to levy buy-back tax under section 115QA of the Income-tax Act, 1961 (the Act). The Tribunal emphasised that tax authorities must look at the transaction as a whole and recognise the statutory distinction between capital reduction and buy-back under the Companies Act, 1956.
The Ministry of Finance has issued Circular No. 87/2026/TT-BTC guiding the 2025 PIT Law and Decree No. 253/2026/ND-CP. The Circular takes effect from 1 July 2026; guidance on employment income for tax residents applies from 1 January 2026. It clarifies the conditions for claiming dependants for family circumstance relief and the PIT treatment of derivative securities transfers.
On 1 July 2026, Vietnam’s new regulations on high technology and strategic technology came into effect, including the Law on High Technology No. 133/2025/QH15, Decree No. 260/2026/ND-CP and other implementing guidance. The new framework introduces notable changes to the incentive regime and development priorities for Vietnam’s high-tech and strategic technology sectors.
The Government issued Decree 239/2026 (“Decree 239”) dated 26 June 2026 amending and supplementing Decree 81/2018 (“Decree 81”) on guiding the Commercial Law on Trade Promotion Activities. Decree 239 introduces several changes aimed at easing administrative requirements and enhancing flexibility for businesses undertaking promotional activities.
The OECD has published a working paper on ‘MNE Responses to the Global Minimum Tax’ which provides early evidence on how MNEs have responded to the introduction of the Global Minimum Tax. The paper assesses the impact on tax rates, investments and employment, and whether there have been adjustments to MNEs’ behaviour in anticipation of the reform.
In this issue:
Tax news
- Government Announces Key Tax Measures under Its Economic Growth Strategy for the Second Half of 2026
- Key Tax and Administrative Changes Taking Effect in the Second Half of 2026
- Ministry of Land, Infrastructure and Transport Selects Five Investment Promotion Zones for 2026
- NTS Extends VAT Payment Deadline by Two Months for Businesses Affected by High Exchange Rates and Other Eligible Taxpayers
Changes in tax laws
- Amended Enforcement Rules of the Corporate Income Tax Law
- Amended Presidential Decree of the Individual Consumption Act
- Amended Rules for the Application of a Tariff-rate Quota under Article 71 of the Customs Act
- Amended Enforcement Rules of the Local Tax Law
Rulings update
- Whether an Underreporting Penalty Applies Where Acquisition Tax Payable Is Underreported Due to an Erroneous Claim of a Tax Reduction or Exemption
- Whether a Tax Incentive Remains Available to a Company in a Special R&D Zone That Has Not Been Re-designated as a High-Tech Enterprise as of the End of the Taxable Year.
On 1 July 2026, the Ministry of Finance issued Circular 95/2026/TT-BTC (“Circular 95”), providing updated guidance on the application of Vietnam’s Double Tax Treaties, Mutual Agreement Procedures (“MAP”) and Advance Pricing Agreements (“APAs”). Circular 95 took effect on 1 July 2026. This Circular replaces Circular 205/2013/TT-BTC on the implementation of tax treaties and Circular 45/2021/TT-BTC on APA.
On 8 July 2026, Treasury released a consultation paper on the Government’s 2026-27 Federal Budget proposal to introduce a 30% minimum tax on discretionary trusts from 1 July 2028.
The European Commission has published a Tax Omnibus proposal that would amend six EU direct tax directives: the Interest and Royalties Directive (2003/49/EC), the Merger Directive (2009/133/EC), the Parent-Subsidiary Directive (2011/96/EU), the Anti-Tax Avoidance Directive (ATAD) (2016/1164), the Dispute Resolution Mechanisms Directive (2017/1852), and the FASTER Directive (2025/50).
The package is intended to simplify the EU direct tax framework, reduce compliance burdens, improve legal certainty, and support EU competitiveness. This Alert focuses on measures that are relevant for the financial sector, including the proposed changes to the Interest and Royalties Directive (IRD), Parent Subsidiary Directive (PSD), FASTER, and ATAD.
The Australian Government has introduced to Parliament the legislation that will reshape how foreign residents are taxed on capital gains (CGT) connected to Australian land and natural resources. The measures form part of the Treasury Laws Amendment (Strengthening Accountability for Tax Adviser Misconduct and Other Measures) Bill 2026 (the Bill) and represent the most significant overhaul of the foreign resident CGT provisions since Division 855 was introduced in 2006.
The Vietnam Government has issued Decree 255/2026/NĐ-CP ("Decree 255") on tax administration for related-party transactions, replacing Decree 132/2020/ND-CP and Decree 20/2025/ND-CP. The new Decree retains the core transfer pricing framework while introducing targeted refinements in several areas of administration and compliance.
The Mumbai bench of the Income-tax Appellate Tribunal (Tribunal), recently, examined whether a demerger will qualify as a tax-neutral demerger where the undertaking is transferred to a resulting company, whereas the shares are issued to the shareholders of the demerged company by the holding company of such resulting company.
On 30 June 2026, the Government issued Decree No. 253/2026/ND-CP guiding the implementation of the Law on Personal Income Tax No. 109/2025/QH15. The Decree is effective from 1 July 2026 and clarifies key changes and supports the implementation of the 2025 PIT Law, including revised taxable income rules, expanded exemptions and reliefs, updated thresholds, and compliance obligations for individuals and employers.
On May 26, the Bureau of Internal Revenue (BIR) issued RMC No. 55-2026, reiterating the obligation of the withholding agents to submit the Alphabetical List of Employees/Payees from Whom Taxes Were Withheld (alphalist) to the BIR on or before the specified due dates.
Greece and Turkey have extended their initial global minimum tax (GloBE) compliance deadlines to ease filing burdens and address stakeholder concerns. Greece postponed the GloBE Information Return (GIR) and notification deadline from 30 June to 30 October 2026 for in-scope MNE groups with financial years ending on or before 31 March 2025. Turkey extended the deadline for global minimum tax returns and related tax liabilities for fiscal 2024 from 30 June to 31 July 2026. In contrast, Germany’s tax authority has confirmed that no deadline extension will be granted.
This edition covers key updates including: - Updates on Federal Budget measures, including new law and consultation - Various State and Territory Budgets - Regulations to support the new Division 296 tax on high super balances.
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