In the current business environment, geopolitical volatility and rapidly evolving business dynamics may require multinational organizations to relocate employees across borders on minimal notice. While such unplanned staff relocations are often essential for business continuity and employee safety, they can inadvertently create tax risks for organizations. Operational decisions made under pressure, such as relocating key personnel during a crisis, may carry unforeseen tax consequences.

This Editorial explores key tax considerations that organizations must address when navigating unplanned employee relocations. From corporate tax issues such as Permanent Establishment (PE) and profit attribution to individual payroll and withholding obligations, understanding these implications is essential. The discussion concludes with practical strategies for proactively managing these risks and ensuring compliance across jurisdictions.

Why Unplanned Staff Relocation Creates Tax Risk

International assignments are typically executed with careful upfront planning, including the establishment of appropriate legal entities, registration with local authorities, and compliance with local payroll withholding and reporting obligations. In contrast, unplanned relocations, such as those prompted by political unrest, natural disasters, or other emergencies, may overlook key planning steps in the rush to safeguard personnel and maintain operations.

What may appear to a company as a temporary or minor adjustment to ensure business continuity can, from a tax authority’s perspective, give rise to a taxable presence. This may expose the business to unexpected corporate tax liabilities or trigger individual income tax obligations for relocated employees.

Permanent Establishment

One of the most significant corporate tax risks arising from unforeseen relocations is the inadvertent creation of a PE in the host jurisdiction. A PE broadly refers to a taxable business presence in a foreign jurisdiction. Where a PE is deemed to exist, the host country gains the right to tax profits attributable to that local presence. A PE may arise in several ways, outlined below:

• Fixed Place PE: One common way a PE arises is through a fixed place of business in the host country, such as an office or other physical site used for business operations on a continuous basis. An employee’s home office may also be considered a fixed place PE if it is used regularly to conduct the company’s business and is effectively at the company’s disposal. The risk is heightened when employee(s) spend a substantial amount of time working from such a location.

Recent OECD commentary[1] on global mobility and remote working provides helpful clarification on how employee presence is assessed for PE purposes but does not offer blanket relief. In practice, not all jurisdictions adopt the OECD’s approach[2], and whether a PE exists depends on the specific facts and circumstances of each case, as well as the interpretation of local law by the relevant authorities.

• Service PE: Certain tax treaties include a service PE clause, under which a company may create a PE where employees or contractors provide services in a country for a specified period. A commonly used treaty threshold is presence exceeding 183 days in a 12-month period, although some treaties or domestic laws provide shorter thresholds.

It is important to note that extended presence may also have implications for individual tax residency. In some jurisdictions, staying 183 days within a given period can result in an individual being treated as a tax resident, giving rise to local tax implications. Unplanned relocations can exceed these day-count limits before companies realize it, particularly when the temporary arrangements are extended due to ongoing uncertainty.

• Dependent Agent PE: A dependent agent PE may arise when a person in the host country habitually negotiates or concludes contracts on behalf of the company or plays the principal role leading to the conclusion of such contracts. When a relocated employee engages in sales activities or finalizes agreements from a temporary host location, the company may be deemed to have a taxable presence in that jurisdiction. Unplanned relocations of senior staff, such as sales personnel or executives who continue to manage client relationships and sign contracts from abroad, are especially susceptible to this risk.

More broadly, the presence of employees in a host jurisdiction may give rise to taxable presence or PE considerations under both domestic law and applicable tax treaties, particularly when relocated personnel are engaged in senior, revenue-generating, or decision-making functions.

Corporate Tax Residency Considerations

Separate from PE risks, unplanned relocations of senior personnel may also raise corporate tax residency considerations. Many jurisdictions and tax treaties apply a Place of Effective Management (POEM) test to determine residency, which looks to where commercial and strategic decisions are effectively made, for example, through senior management or board-level decision-making.

When senior executives temporarily relocate and continue to exercise decision-making authority from a host jurisdiction, there is a risk that tax authorities may seek to assert corporate tax residency in that jurisdiction. 

In summary, identifying and managing these risks is critical. The inadvertent creation of a PE or corporate tax residency under POEM can give rise to corporate income tax exposure, along with associated corporate tax filings and reporting requirements.

Transfer Pricing and Attribution of Profits to the PE

Cross-border relocations can shift the location of value creation and control, which may in turn raise questions about the attribution of profits under the Authorized OECD Approach (i.e., aligning profits with functions performed, assets used, and risks assumed in the host jurisdiction).

In particular, when relocated personnel undertake senior, revenue-generating, or decision-making functions, existing transfer pricing models or intercompany agreements may no longer reflect commercial reality. 

When a PE arises from unplanned relocation, the key challenge shifts to profit attribution. If business activities are effectively carried out in another jurisdiction, an appropriate share of profits may need to be allocated and taxed locally, reflecting the value of functions performed and decisions undertaken there, as if the PE were a separate enterprise.

Accordingly, organizations should proactively review TP policies, intercompany arrangements, and “ways of working” controls, such as RACI frameworks, operating protocols, and contemporaneous supporting documentation, to ensure alignment between intended structures and actual conduct.

Employment Taxes and Payroll Exposure

Unplanned staff relocations may also raise employment tax and payroll compliance challenges. When an employee performs work in another country, even on a short-term basis, there may be personal income tax and social security implications, together with employer reporting and withholding obligations. If an employee meets the host country’s criteria for tax residency, for example, by exceeding a certain number of days or engaging in local service delivery, the host jurisdiction may assert taxing rights over the individual’s income.

Employers may also be required to register with local tax authorities and operate payroll withholding in the host jurisdiction, which can create operational challenges when no local entity or payroll infrastructure exists. Failure to comply with local reporting and withholding requirements may result in tax, interest, and penalty exposure.

Managing Risk

To manage tax risks arising from unplanned staff relocations, organizations should adopt a structured and coordinated approach. Internal policies should define permissible durations of stay, permitted activities, and escalation procedures. Cross-functional coordination among Tax, Human Resources, Legal and Payroll teams is essential to track employee presence, activities and time spent in host locations. Governance mechanisms may include pre-travel clearance processes or, where appropriate, formal arrangements, such as secondment agreements. Comprehensive documentation of employee activities, locations, and business purposes should be maintained to support the organization’s tax positions in the event of scrutiny.

When relocations evolve into semi-permanent arrangements, companies should be prepared to reassess their operating models. Depending on the facts and circumstances, this may involve structural changes, such as establishing local legal entities or revisiting transfer pricing arrangements.

The objective is not to discourage urgent relocations but to ensure that appropriate considerations are built into the decision-making and oversight process, helping to minimize unforeseen exposures and protect the business as circumstances evolve.

USA

March 06, 2026: US Proposes To Eliminate Partnership Basis‑Shifting Disclosure Requirements[3]

The US Treasury Department and the Internal Revenue Service (IRS) have issued proposed regulations to remove the special disclosure regime for partnership transactions involving basis shifting. The proposal would roll back rules introduced in January 2025 that required partnerships to treat certain related-party transactions such as distributions, contributions, and tiered partnership arrangements as transactions of interest, subject to detailed reporting. If finalized, partnerships, partners, and material advisors would no longer be required to file dedicated basis shifting disclosure forms, though partnerships would continue to report basis adjustments required under existing tax rules. The proposed change follows widespread concerns from taxpayers and advisors that the prior regime was overly complex, burdensome, and retroactive, and it builds on earlier penalty relief announced by the IRS. Treasury and the IRS have indicated that the repeal would be treated as effective from January 14, 2025, effectively deeming the prior reporting regime never to have applied.

March 01, 2026: Washington Offers Penalty Relief for Sales and Use Tax on Newly Taxed Services[4]

The Washington Department of Revenue has announced a temporary retail sale and use tax penalty relief program to help businesses transition to changes introduced under ESSB (Engrossed Substitute Senate Bill) 5814, which expands the applicability of sales tax to certain services, effective October 01, 2025. The program waives penalties on uncollected retail sales tax and unpaid use tax attributable to ESSB 5814 for reporting periods from October 01, 2025, through December 31, 2026, provided businesses pay the underlying tax and any applicable interest. Penalty relief is not available in cases involving tax evasion, tax avoidance, or negligence. Eligible businesses must apply by September 30, 2027, and for pre‑existing contracts that were subject to temporary sales tax relief, penalty relief applies from the earlier of the date that temporary relief ends or April 01, 2026.

March 11, 2026: New Mexico Enacts Significant Revisions To Corporate Income Tax Framework[5]

Senate Bill 151, enacted in New Mexico, significantly revises the state’s corporate tax regime by reducing conformity with certain federal tax provisions and broadening the corporate income tax base. The legislation requires addbacks for federal bonus depreciation and qualified production property expensing when calculating state taxable income, replaces the EBITDA‑based limitation on business interest deductions with a more restrictive EBIT‑based approach, and expands the tax base to include certain Net Controlled Foreign Corporation Tested Income (NCTI) aligning with the federal transition from Global Intangible Low-Taxed Income (GILTI) to NCTI. In parallel, the bill introduces and extends targeted incentives, including income tax credits for physicians and local news organizations, a gross receipts tax deduction for affordable multifamily housing construction, and an extension of the high‑wage jobs tax credit. The measures are expected to increase state tax revenues and will most affect capital‑intensive, highly leveraged, and multinational businesses, with most provisions applying to tax years beginning on or after January 01, 2027, subject to specific effective date exceptions for certain incentives.

March 18, 2026: IRS Extends Relief on Digital Asset Identification Requirements[6]

The Internal Revenue Service Notice 2026-20 extends temporary relief that gives taxpayers additional flexibility in identifying digital assets (e.g., cryptocurrencies) in the custody of their brokers that are sold or transferred, acknowledging additional time brokers need to complete required systems. The notice extends this relief period for one additional year, through December 31, 2026, allowing taxpayers to rely on their own books and records, and is intended to give additional time for both taxpayers and brokers to adapt to evolving digital asset reporting rules while ensuring smoother compliance during the transition period.

March 18, 2026: IRS Creates Limited Opportunity To Revisit “Irrevocable” §163(j) Elections[7]

The IRS (Rev. Proc. 2026-17) allows eligible taxpayers to retroactively withdraw certain irrevocable Section 163(j)(7) elections and make late bonus depreciation elections as a result of OBBBA changes, generally by filing amended returns by the earlier of October 15, 2026, or the end of the applicable limitations period.

Please refer to A&M Tax Alert[8] for detailed analysis.

Canada

March 02, 2026: Prime Minister’s Office Announcements Related To Tax and Trade With India

Prime Minister Carney and Prime Minister Modi released a joint statement announcing five Memorandums of Understanding (MOUs) and a broad range of initiatives to renew and expand the Canada-India partnership across energy and critical minerals, technology and AI, talent and culture, and defense. This included an announcement that Canada and India will conclude a new Comprehensive Economic Partnership Agreement (CEPA) this year. CEPA will advance Canada’s goal to more than double two-way trade to $70 billion by 2030. To leverage their strengths as complementary economies, Canada and India announced a new Strategic Energy Partnership, including in LNG, LPG, uranium, solar, and hydrogen. As first steps, the leaders welcomed:

• A landmark $2.6 billion agreement between the Government of India and Cameco Corporation to supply nearly 22 million pounds of uranium to India for nuclear energy generation from 2027 to 2035.
• Two MOUs to intensify cooperation on critical minerals and energy sources, supporting technical and commercial engagement and diversifying supply chains.
• Strengthened collaboration on clean energy initiatives in solar, wind, biofuels, and hydropower, including announcing that Canada intends to join the International Solar Alliance and is upgrading to full membership status in the Global Biofuels Alliance.
• Intensified engagement on LPG with the aim to conclude Canada’s first long-term LPG arrangement with India.

March 05, 2026: Prime Minister’s Office Announcements Related To Tax and Trade With Australia

Prime Minister Carney and Prime Minister Albanese released a joint statement outlining new partnerships in investment, defense and security, critical minerals, energy, and artificial intelligence (AI). The leaders also launched a new Clean Energy Partnership to catalyze new trade and investment opportunities, scale-up clean energy technologies, and modernize electricity grids.

Australian superannuation funds and Canadian pension funds and investment corporations and boards entered into a Memorandum of Understanding (MOU) under the Canadian Australian Pension Funds Investment Initiative (CAP Invest Initiative) intended to remove barriers to investment and foster investment in both countries. The initiative includes Australian Retirement Trust, AustralianSuper, Aware Super, CareSuper, Cbus Super Fund, HESTA, Hostplus, IFM Investors, and Rest, as well as the following Canadian funds/organizations: Alberta Investment Management Corporation (AIMCo), BCI, La Caisse (Caisse de dépôt et placement du Québec), CPP Investments, HOOPP (Healthcare of Ontario Pension Plan), Investment Management Corporation of Ontario (IMCO), OMERS, Ontario Teachers' Pension Plan, and PSP Investments.

Prime Minister Carney and Prime Minister Albanese also agreed to launch negotiations to modernize the Canada-Australia Tax Treaty to facilitate increased two-way investment between Canada and Australia.

March 26, 2026: Budget Implementation Bill Receives Royal Asset[9]

On March 26, 2026, Bill C-15, the Budget Implementation Act, 2025 (No. 1), received Royal Assent. This bill enacts into law a number of significant, previously announced tax measures, including accelerated capital cost allowance measures and various refundable clean economy investment tax credits, updated transfer pricing rules, tax compliance measures related to trust and bare trust filing requirements, enhancements to the federal Scientific Research and Experimental Development (SR&ED) tax credit, and the proposed changes to certain share exchanges and foreign mergers involving foreign affiliates.

Belgium

March 12, 2026: Belgium Implements DAC8[10]

The Belgian Parliament has passed legislation implementing DAC8, the amending directive to the 2011 Directive on Administrative Cooperation (2023/2226), to introduce expanded reporting and information sharing obligations for cryptocurrency assets and electronic money with retroactive effect from January 01, 2026. Under the rules, crypto asset service providers must collect and report detailed data on EU resident users and their transactions, including gross payments and fair market values, with the first reporting due by June 30, 2027, for the 2026 calendar year, followed by the automatic exchange of this information among EU tax authorities. The legislation also broadens the automatic exchange of certain advance cross border tax rulings involving individuals, strengthens due diligence and disclosure requirements, and establishes a comprehensive penalty framework for non compliance, while allowing confidentiality protections for lawyers. The bill will now be submitted for royal assent followed by gazette notification.

March 17, 2026: Belgium Launches Public Consultation on Income Inclusion Rule Top-Up Tax Returns[11]

Belgium launched a public consultation to gather feedback on declarations and explanatory notes relating to Pillar Two under the Income Inclusion Rule (IIR), covering both the supplementary tax return under the qualified IIR and the IIR surcharge (additional levy) return for tax/assessment years 2024 and 2025. The draft forms and explanatory materials address key aspects such as taxpayer identification, reporting for multinational enterprises (MNEs) and large domestic groups, tax calculation, advance payment obligations and an increase in the top-up tax in cases of insufficient advance payments. The consultation period ran from March 17, 2026 (for qualified IIR) and March 19, 2026 (IIR surcharge), to April 03, 2026, and comments may be submitted by email to pillar2@minfin.fed.be with subject lines referring to the supplementary tax return under the qualified IIR or the IIR surcharge return, as applicable.

March 17, 2026: Belgium Updates Transfer Pricing Circular To Incorporate OECD Pillar One Amount B Guidance[12]

The Belgian tax authorities have issued an addendum to Circular 2020/C/35 to reflect the OECD’s February 2024 report on Pillar One, Amount B. The addendum confirms Belgium’s acceptance, under strict conditions, of the Amount B outcome where it is applied by a ‘covered jurisdiction’ in line with the OECD guidance and a double tax treaty exists, while clarifying that the approach does not apply to in-scope transactions performed in Belgium itself. It sets out the scope of eligible transactions, exclusions, use of the transactional net margin method (with limited acceptance of comparable free market price), the pricing matrix methodology, adjustment mechanisms, documentation expectations, and implications for MAP and arbitration. The addendum does not amend existing OECD transfer pricing principles as reflected in Circular 2020/C/35, and will apply to relevant transactions and permanent establishment dealings from January 01, 2025.

March 23, 2026:Belgium Tax Authorities Issue Modified Draft Templates for Domestic Minimum Top‑Up Tax Returns[13]

Belgium’s tax authority has released revised draft materials, including templates, the XSD scheme and explanatory memoranda for Domestic Minimum Top‑Up Tax (DMTT) returns for 2024 and 2025, aligning them more closely with the OECD’s GloBE Information Return template while limiting disclosures to DMTT requirements. Filing is restricted to groups registered for Pillar Two/GloBE purposes in Belgium, with the first deadline on June 30, 2026.

Czech Republic

March 05, 2026: ECJ Permits Retrospective Withholding Tax Exemption Without Time Limits[14]

On March 05, 2026, the Court of Justice of the European Union, in Case C-828/24, clarified that, under the EU directive on a common system of taxation applicable to interest and royalty payments made between associated companies of different Member States (Directive 2003/49/EC), a source Member State may grant a withholding tax exemption retroactively, including for periods prior to the formal exemption decision or the submission of required attestations and supporting information. The Court further held that the directive does not prescribe any time limit for providing such documentation, nor does it restrict the length of the prior period for which an exemption may be granted.

Finland

March 01, 2026: Government Sets Out Fiscal Plan for 2027–2030[15]

The Finnish Ministry of Finance has published a proposal outlining its fiscal framework for the period 2027–2030, projecting an annual budget deficit of EUR 14.9 billion over the period. To address this gap, the proposal identifies measures aimed at generating EUR 10 billion per year through spending reductions and tax reforms. Proposed measures include continued indexation of personal income tax brackets for inflation, a targeted reduction in taxation of employment income for low- and middle-income individuals, and a reduction in the corporate income tax rate from 20% to 18%, effective 2027. The proposal is scheduled for further discussion, with a final decision expected by April 30, 2026.

March 5, 2026: Amendments to Finland’s Pillar Two Minimum Tax Law Adopted[16]

The Finnish Parliament approved legislative proposals HE 196/2025 and HE 6/2026, which amend the Law on the Minimum Tax for Large Groups governing the implementation of the OECD’s Pillar Two global minimum tax rules. The adopted measures adjust Finland’s existing Pillar Two framework, building on earlier government proposals, to refine and clarify the application of the minimum effective tax regime for large multinational and domestic groups in line with evolving international standards.

France

March 16, 2026: France Tightens Dividend Withholding Rules to Counter Dividend Arbitrage Scheme[17]

The French tax authorities have released guidance on newly enacted anti‑dividend arbitrage rules effective January 01, 2026, introduced by the Finance Law for 2025 through Article 119 bis A (II) of the General Tax Code. Aimed at countering dividend-arbitrage schemes, these rules require French companies to apply the domestic dividend withholding tax rate at source when distributing dividends to residents of countries meeting the specified conditions. The guidance clarifies that, in practice, these measures apply to treaties with Bahrain, Egypt, Finland, the UAE, Kuwait, Lebanon, Oman, Qatar and Saudi Arabia, where the relevant tax treaty provides a full exemption from, or non‑application of, withholding tax without any participation threshold. Refunds may be claimed only if the non‑resident recipient substantiates tax residency under the treaty and, beneficial ownership (where applicable).

March 25, 2026: France Releases Supplementary Tax Form 2272 SD Under Pillar Two[18]

The French tax authorities have advanced the operational rollout of Pillar Two by publishing Form n°2272 SD, the official return for the computation and payment of the Pillar Two supplementary (Top-Up) tax in France. The authorities also clarified how this supplementary tax return interacts with the Global Information Return (GIR), confirming that French entities liable for Pillar Two tax must file Form 2272 SD in line with the GIR filing framework and the applicable centralized filing rules.

Germany

March 24, 2026: Proposed Ratification of CRS MCAA Addendum[19]

The Ministry of Finance released a draft bill seeking ratification of the Addendum to the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (CRS MCAA), reflecting updates introduced under the 2023 revised Common Reporting Standard.

March 24, 2026: Draft Bill for Ratification of CARF MCAA[20]

Germany’s Ministry of Finance released a draft bill proposing the ratification of the Multilateral Competent Authority Agreement on Automatic Exchange of Information pursuant to the Crypto‑Asset Reporting Framework (CARF MCAA). The CARF MCAA establishes a standardized legal framework for the automatic exchange of tax relevant information on crypto‑asset transactions in line with the OECD‑developed Crypto‑Asset Reporting Framework (CARF), including related reporting and due diligence obligations. Together, the CARF and the CARF MCAA are intended to address tax transparency challenges arising from the rapid growth of crypto‑asset markets and to align crypto‑asset reporting with global information‑exchange standards.

Greece

March 12, 2026: Greece Clarifies Notification Process for Pillar Two Top‑Up Tax Reporting[21]

The Independent Authority for Public Revenue (AADE) has issued guidance on the notification required for the Top‑Up Tax Information Return under Greece’s Pillar Two rules. Greek constituent entities must electronically inform the tax authorities, through the myAADE portal, of which entity will file the return and the country where that entity is located. The notification is due within 15 months from the end of the fiscal year (extended to 18 months for the first year in scope), must be filed by a designated local entity where there are multiple Greek entities, and does not need to be filed again in later years if there is no change in the information.

Ireland

March 24, 2026: Revenue Updates Pillar Two Guidance on Tax Losses[22]

Irish Revenue has issued updated Tax and Duty Manuals under the Pillar Two regime, clarifying the treatment of loss related deferred tax assets (DTA) and other key technical and administrative aspects. The guidance confirms that loss related DTAs may only be recognized as adjusted covered taxes only when the underlying losses genuinely reverse and are utilized, while pre Pillar Two DTAs must be treated as transition DTAs and unwound over time. Further clarifications address the treatment of orphan entities, permit greater flexibility in allocating Under Taxed Profits Rule top-up tax where payment is made on time, confirm that DTAs from government provided tax benefits fall within the transitional CbCR safe harbor, and allow the use of local accounting standards for domestic top-up tax despite differing fiscal year ends. In parallel, updated administrative guidance reinforces enhanced documentation requirements, requiring MNE groups to retain detailed workpapers supporting Pillar Two calculations, elections, and allocations.

March 25, 2026: Revenue Issues Updated Guidance on Participation Exemption for Foreign Distributions[23]

Irish Revenue has issued updated guidance on the participation exemption, clarifying eligibility for dividends paid from non-European Economic Area or non‑tax treaty jurisdictions. The guidance confirms that, for distributions made on or after January 01, 2026, from companies resident in these jurisdictions, the exemption qualification may apply if a nominal foreign withholding tax greater than zero percent applies to the full amount of distribution and is not refunded. Other key changes include shortening the relevant and reference periods from five years to three years; determining residential status via applicable tax treaties when domestic law is unclear, allowing companies in new treaty‑partner jurisdictions to qualify as relevant subsidiaries from the treaty signature date, and offering flexibility for certain mergers, acquisitions involving an Irish company and changes in place of residence from Ireland for distributions made on or after January 01, 2025.

Italy

March 3, 2026: WHT Discrimination on Outbound Dividends[24]

The Italian Supreme Court issued a decision confirming that applying a higher withholding tax (WHT) to outbound dividends paid to non-resident shareholders compared to the effective tax burden on comparable Italian corporate recipients constitutes a breach of Article 63 TFEU (free movement of capital). Crucially, the Court rejected the argument that "compensatory advantages" in the recipient's country of residence (e.g., foreign tax credits) could offset this discrimination. This ruling opens a strong pathway for EU (and potentially non-EU) investors, to claim historical WHT refunds from the Italian Treasury.

March 20, 2026: Participation Exemption Denied Where Subsidiary Carries Out Only Preliminary Activities[25]

The Italian Supreme Court held that capital gains on the sale of shares do not qualify for the participation exemption where the subsidiary’s activity is limited to preparatory or organizational steps and has not resulted in the effective exercise of a commercial enterprise. In a real estate redevelopment case, the Court ruled that activities such as planning procedures, obtaining permits, financing arrangements, and asset enhancement are insufficient on their own unless accompanied by the actual and uninterrupted conduct of income producing business operations throughout the statutory holding period. Overturning the lower courts, the Court confirmed that a mere organizational structure or potential to operate does not satisfy the participation exemption requirements, reinforcing that the exemption applies only to subsidiaries engaged in genuine business activity.

Luxembourg

March 16, 2026: Luxembourg Expands CbC Reporting Exchange Network[26]

Luxembourg has issued an amended Grand‑Ducal Regulation updating the list of jurisdictions eligible for the automatic exchange of Country‑by‑Country (CbC) reports with the Luxembourg tax authorities. The update adds the Dominican Republic, Mongolia, Senegal, and Tunisia to the exchange framework and was published in the Official Gazette on March 16, 2026.

March 27, 2026: Luxembourg Enacts DAC8 Law Extending Tax Transparency to Crypto Assets[27]

Luxembourg has enacted legislation transposing DAC8 (Directive (EU) 2023/2226), effective retroactively from January 01, 2026, significantly expanding automatic exchange of information obligations. The law introduces due diligence, registration, and annual reporting requirements for EU and non‑EU crypto‑asset service providers with a Luxembourg nexus, covering a broad range of crypto‑related activities and EU‑resident users, subject to limited carve‑outs. Reported crypto‑asset information will be exchanged between tax authorities from 2026 onward, alongside new exchanges relating to income from cross‑border life‑insurance payouts and certain high‑value or residence‑determining advance tax rulings for individuals. The legislation also integrates excluded crypto products, such as electronic money and central bank digital currencies, into the existing CRS framework and reduces DAC7 reporting where verified identification services are used. In addition, it aligns DAC6 professional secrecy rules with recent European Court of Justice case law, narrowing lawyers’ notification obligations while preserving client disclosure requirements. The exchanged information may also be used for customs enforcement and anti‑money‑laundering, and counter‑terrorism purposes.

Lithuania

March 20, 2026: Lithuania Updates Guidance on Tax Treatment of Profit Distributions and Dividends[28]

Lithuania’s tax authority updated its Corporate Income Tax guidance, providing clarity on profit distributions and dividend treatment. Profits distributed by unlimited liability entities (e.g., partnerships) are exempt at the corporate recipient level only to the extent they arise from income already subject to corporate income tax. If the distributing entity earns both taxable and non-taxable income, the exemption applies proportionately, and the portion linked to non-taxable income must be taxed. The guidance also confirms that dividends received and then redistributed by such entities retain their nature as dividends and are generally exempt for corporate recipients, subject to standard dividend exemption conditions and traceability requirements. Additional clarifications include the eligibility of profits from foreign entities for exemption where an equivalent tax is paid, an exemption for certain pension funds from dividend taxation (with no withholding obligation), and specific cases where dividend payments to trustees fall outside standard dividend-tax rules.

Poland

March 17, 2026: Poland Enacts Law Implementing DAC8 and DAC9[29]

Poland enacted legislation amending its tax information exchange framework to incorporate the Amending Directive to the 2011 Directive on Administrative Cooperation (2023/2226) (DAC8) and the Amending Directive to the 2011 Directive on Administrative Cooperation (2025/872) (DAC9) into domestic law. The law formalizes updated EU rules on administrative cooperation, particularly expanding reporting and information exchange requirements. It was published on March 17, 2026, in the Official Journal of Laws.

March 12, 2026: Government Seeks Input on GloBE Information Return Framework[30]

The Minister of Finance released a draft regulation for consultation, outlining detailed data requirements for the GloBE Information Return under the top-up tax law of November 6, 2024. Based on the OECD/G20 framework, the return is designed to support tax authorities in risk assessment and is divided into two parts: a general section (covering group-level details, structure, and the reporting entity) and a jurisdictional section (covering country-specific data). The latter includes information on safe harbors, exclusions, effective tax rate calculations, top-up tax (if any), its allocation, and details relevant to the qualified domestic minimum top-up tax (QDMTT). The draft, published on March 12, 2026, is open for stakeholder feedback. The final regulation will be issued after consultation and will take effect upon publication.

Netherlands

March 01, 2026: Guidance Issued on Permanent Establishment Definition Under the Minimum Tax Act 2024[31]

Knowledge Group has clarified that, under Article 1.2(1)(a) of the Netherlands’ Minimum Tax Act 2024 (WMB 2024), a permanent establishment qualifies as a ‘treaty permanent establishment (PE)’ only where specified conditions are met. First, there must be a PE under the relevant tax treaty. In addition, the state where the PE is located must actually tax the income attributable to it under its domestic law. It is not enough that the treaty merely allows that state to tax the income, the income must be taxed on a net basis using rules comparable to Article 7 of the OECD Model Tax Convention. This requires application of the functionally separate entity approach and taxation comparable to that of resident entities. Gross-basis taxation, such as withholding tax, is not sufficient. This interpretation is consistent with the OECD Pillar Two Model Rules and related commentary.

March 01, 2026: Dutch Supreme Court Rules on General Three-Year Anti-Abuse Provision for Demerger Shares Disposal[32]

The Supreme Court of the Netherlands, in X NV vs. State Secretary for Finance, ruled that the statutory presumption under Dutch corporate tax law, which assumes a demerger lacks valid business reasons if shares are disposed of within three years, is incompatible with the EU Merger Directive. The Court held that this presumption operates as a general anti-abuse rule and cannot be applied without the tax authorities first demonstrating indications of tax avoidance or the absence of commercial justification. It further clarified that the burden of proof cannot automatically shift to the taxpayer solely due to the timing of the disposal.

March 02, 2026: Netherlands Consults on Currency Hedging Tax Treatment[33]

The Dutch government launched a public consultation on draft legislation amending the tax treatment of foreign exchange results on hedging instruments under the participation exemption. The consultation closed on March 30, 2026. It proposes that, for financial years starting January 01, 2027, onward, only non-discounted currency results from legal hedging transactions qualify for the exemption, excluding priced-in currency results. This measure is intended to be included in the 2027 Tax Plan, with effect from January 01, 2027.

March 06, 2026: Dutch Government Outlines Next Steps for Box 3 Tax Reform[34]

The Dutch government, in a letter dated March 06, 2026, informed Parliament about the status of the proposed Act on Taxation of Actual Return in Box 3 bill relating to the taxation of savings and investment income. The bill, approved by the Lower House in February 2026 and now under consideration by the Upper House, proposes replacing the existing deemed return system with taxation based on actual returns from 2028. The government is also considering potential modifications to the proposal, including a one-year loss carry-back mechanism (per the motion passed by the Lower House on February 26, 2026), while simultaneously developing a system that would tax gains upon realization to be introduced after 2028.

March 31, 2026:Upper House Approves DAC8 Implementation Bill[35]

The Upper House has passed legislation to implement the Amending Directive to the 2011 Directive on Administrative Cooperation (2023/2226) (DAC8) retroactively from January 01, 2026. The law introduces mandatory reporting and data sharing obligations in respect of electronic money and crypto-assets. Crypto service providers and intermediaries must submit client information to the tax authorities annually by January 31 of the following year, with 2026 data due by January 31, 2027. The bill also expands information exchange on certain high value cross border rulings for individuals and residency determinations, with significant penalties for non-compliance.

Norway

March 19, 2026: Norway Clarifies Value Added Tax Treatment of Data Centre Services[36]

The Tax Appeals Board has confirmed that data center services provided to foreign business customers must be treated as separate supplies of goods and services, each subject to its own Value Added Tax (VAT) assessment. It rejected the view that these services form a single VAT-exempt supply, stating that, while some digital elements may qualify as remotely delivered services, physical components, such as storage, cooling, electricity, and security, are location specific and taxable. The Board also clarified that such on-site services are considered supplied and consumed domestically, even if the customer is based abroad. The decision aligns with European Union VAT principles and highlights the need to distinguish between remote and physical elements in data center arrangements.

Spain

March 12, 2026: Spain Releases Annual Tax and Customs Control Plan for 2026[37]

Spain’s Ministry of Finance has approved the Annual Plan for Tax and Customs Control 2026 (Resolution of March 11, 2026), setting out key compliance priorities while largely retaining the existing five-pillar framework. The plan places stronger emphasis on data analytics, the digital economy and new financial intermediation, including expanded use of predictive models, automated risk selection, and enhanced information exchange (notably Pillar Two reporting under DAC9 and future DAC8). Key focus areas include strengthened taxpayer assistance and digital services, intensified controls over transfer pricing, tax incentives, digital services and financial transaction taxes, real estate and expatriate regimes, crypto assets, and ecommerce, as well as reinforced fraud collection measures and international cooperation. Coordination with regional tax authorities will also be enhanced to improve compliance, reduce fraud, and increase legal certainty. These are the most significant actions to be carried out under the Spanish Tax Authorities’ 2024–2027 Strategic Action Plan.

Sweden

March 01, 2026: Sweden Invites Feedback on New R&D Tax Incentive Options[38]

The Swedish Ministry of Finance has released a memorandum for public consultation on Research and Development (R&D) tax incentives, following an inquiry into the country’s R&D tax framework. The memorandum proposes two distinct models: a higher deduction for eligible expenses and a refundable tax credit, limited to salary-related R&D costs. The memorandum aligns these approaches with the OECD/G20 Inclusive Framework’s adopted ‘side-by-side package,’ which is confirmed under the European Commission’s Minimum Taxation Directive (2022/2523). Responses to the consultation are due by April 23, 2026.

United Kingdom

March 10, 2026: UK Releases Consultation To Modernize and Standardize Company Tax Returns[39]

His Majesty's Revenue and Customs (HMRC) has launched a consultation on standardizing corporation tax computations in prescribed formats for filing with company tax returns to enhance data quality and consistency, replacing current free-format XBRL-tagged submissions. It also proposes mandatory online filing of amendments to company returns, replacing written submissions. The consultation seeks feedback on the implementation timeline and enforcement mechanisms, with responses due by June 02, 2026.

March 12, 2026: HMRC Consults on Expanding Scope of Uncertain Tax Treatment Regime[40]

HMRC has launched a consultation on proposed changes to broaden the scope of the Uncertain Tax Treatment regime, which currently requires large businesses to notify the tax authority of legal interpretation uncertainties. The proposals extend the regime to include additional taxes, such as stamp duty land tax, National Insurance contributions, inheritance tax, and capital gains tax. The consultation also considers bringing wealthy individuals and trusts within scope where an uncertain tax treatment may result in a tax advantage exceeding GBP five million. Open until June 04, 2026, the consultation is expected to inform future legislative changes, with potential implementation through a forthcoming Finance Bill for returns filed after April 1 of the following year.

March 17, 2026: UK Updates Country-by-Country Reporting Guidance[41]

HMRC updated its guidance on country-by-country reporting (CbCR) for large multinational enterprises (MNEs) with revenues exceeding EUR 750 million. The update provides new and revised instructions on identifying entities within scope, registering for CbCR, and submitting reports in XML format. It also clarifies that agents must now be formally authorized to file on behalf of clients using a ‘digital handshake’ process. Overall, the guidance enhances clarity regarding compliance requirements, reporting procedures, and agent authorization. It was published on March 17, 2026.

March 18, 2026: UK Finance Act 2026 Enacted Following Royal Assent[42]

The Finance Act 2026, has now been enacted following the grant of Royal Assent, formally giving legal effect to a wide range of tax measures first announced in Budget 2025. Key provisions include reforms to inheritance tax reliefs for businesses, agricultural property, and pensions, and higher taxation of dividends and capital gains, alongside amendments to capital allowances. The Act also restricts reliefs for disposals to employee‑ownership trusts, makes Making Tax Digital (MTD) compulsory for income tax, and introduces compliance requirements for umbrella companies.

March 23, 2026:HMRC Rolls Out Making Tax Digital Implementation Regulations[43]

HMRC published the Income Tax (Digital Obligations) Regulations, advancing the rollout of MTD for income tax, which mandates compatible software for digital records and submissions on business/property income from April 01, 2026, under the Finance Act 2026. The regulations initially apply to sole traders and individuals with property income exceeding GBP 50,000 in the 2024/25 tax year, dropping to GBP 30,000 in the 2025/26 tax year, with a proposal to further reduce the threshold to GBP 20,000 from April 2028.

March 27, 2026: Amendment Order Relating to Section 4A of the Social Security Contributions and Benefits Act 1992 [44]

SI 2026/341 updates section 4A of the Social Security Contributions and Benefits Act 1992, following the introduction of Chapter 11 of Part 2 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003) by the Finance Act 2026. The Order inserts a new subsection (2C), enabling regulations to impose joint and several liability for National Insurance contributions on specified persons, alongside an umbrella company, where linked income tax liabilities arise under ITEPA 2003. It also facilitates the collection and recovery of those contributions and aligns contributions treatment where an individual is regarded as employed by a ‘purported umbrella company’ for income tax purposes. Additional amendments broaden related regulation-making powers and introduce a statutory definition of ‘umbrella company’ by reference to ITEPA 2003. The Order comes into force on March 26, 2026.

China

March 12, 2026: Policy driver - National People’s Congress Confirms Fiscal and Tax Policy Direction[45]

In March 2026, China’s National People’s Congress (NPC), the country’s annual legislative session that sets the macroeconomic and fiscal policy agenda, confirmed a proactive fiscal stance for 2026, including a higher fiscal deficit ratio and continued issuance of special government bonds to support economic growth. On tax policy, authorities emphasized implementation of the new VAT Law, continued, targeted tax incentives for priority sectors, stronger tax administration and enforcement, and advancing Consumption Tax reform, including potential adjustments to the scope of taxable goods and revenue allocation between central and local governments.

Korea

March 01, 2026: Korea Updates Tax Framework Through Enforcement Decrees[46]

The Republic of Korea has issued a package of Presidential Enforcement Decrees to operationalize recent tax law changes, including implementation of the OECD Pillar Two rules, updates to tax incentives, and revisions affecting foreign enterprises. The measures introduce detailed rules on the calculation, allocation, and reporting of Korea’s domestic top‑up tax, prescribe additional details for existing income tax incentives applicable to high‑tech businesses in designated R&D zones, and broaden the scope of exit taxation to cover additional asset classes, including foreign shares. The amendments also strengthen compliance requirements for foreign liaison offices, align agent permanent establishment rules more closely with the OECD Model by tightening the conditions under which agents create a taxable presence, and narrow the application of the deemed capital regime for foreign bank branches by excluding branches that fall within prescribed thin capitalization thresholds.

Hong Kong

March 01, 2026: HKICPA Tax Bulletin Highlights IRD Positions on FSIE, FIHV and Key Tax Administration Matters[47]

The Hong Kong Institute of Certified Public Accountants (HKICPA) has released the minutes of its 2025 annual meeting with the Inland Revenue Department (IRD) in its March 2026 Tax Bulletin, outlining the IRD’s views on a range of practical tax issues. The discussion covers key aspects of the Foreign-sourced Income Exemption (FSIE) regime, certificates of resident status and interest deductibility, as well as interpretative matters under the Family-owned Investment Holding Vehicle (FIHV) regime, including lease reinstatement costs and minimum asset thresholds. The minutes also provide guidance on identifying “embedded Intellectual Property (IP) income” for the patent box concession by reference to OECD transfer pricing principles, and address selected salaries tax, transfer pricing disclosure, and broader tax administration matters.

India

March 05, 2026: India Broadens Tax Transparency Framework under FATCA and CRS[48]

India announced amendments to its Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS) information‑reporting regime, expanding the range of assets and entities subject to reporting. The updated framework brings crypto assets (including derivatives), central bank digital currencies, and specified electronic money products within the reporting net, broadens the scope of depository accounts and institutions holding such assets, and introduces enhanced due diligence and reporting requirements, including self‑certification, identification of joint holders and controlling persons, and income disclosures. The changes also expand the scope of excluded accounts, extend non‑reporting status to qualified non‑profit entities, and define criteria for distinguishing between pre‑existing and new accounts. The amendments take effect from January 01, 2026.

March 20, 2026: CBDT Notifies New Income‑tax Rules to Support the Upcoming Tax Framework[49]

The Central Board of Direct Taxes (CBDT) has issued the Income tax Rules, 2026, in advance of their implementation from April 01, 2026, to operate alongside the Income‑tax Act, 2025. The new rules are intended to modernize the tax framework by simplifying drafting style, facilitating compliance, reducing the potential for disputes, and eliminating provisions that are no longer relevant. They also introduce greater reliance on structured tables, standardized formats, and formula‑driven approaches to enhance clarity and consistency in tax administration.

March 25, 2026: ITAT Delhi Treats Group Buy‑Back as Reorganisation Under India–Netherlands Treaty[50]

The Delhi ITAT held that a share buyback undertaken as part of an internal group restructuring qualifies as a ‘corporate reorganization’ under Article 13(5) of the India–Netherlands tax treaty. It found that such a buyback represents a substantive alteration of the company’s capital structure rather than a simple share transfer. Accordingly, capital gains arising from the transaction were held taxable only in the Netherlands. The ruling clarifies that treaty protection can extend to genuine internal buybacks even without a court approved scheme.

March 31, 2026:India’s Finance Act, 2026 Gazetted Following Presidential Assent[51]

Following Presidential assent to the Finance Bill, passed by both the Lok Sabha and the Rajya Sabha, the Finance Act 2026 has been enacted and was notified in the Gazette of India on March 31, 2026. The Act gives effect to a range of Budget 2026 proposals spanning corporate income tax, transfer pricing, IFSC‑related tax measures, personal income tax, and indirect taxes, including GST and customs duties. It also incorporates several revisions made during the parliamentary process including a 12% cap on surcharge applicable on the additional tax payable by promoters on income from share buybacks, an increase in the startup tax holiday turnover threshold from INR one billion to INR three billion, enhanced powers for tax authorities to reopen certain assessments, a minimum 30‑day response period for reassessment notices, and provisions allowing waivers of specified interest, penalties, and arrest‑related measures. It also incorporates several revisions made during the parliamentary process. The Finance Act, dated March 30, 2026, was notified in the Gazette of India on March 31, 2026.

March 31, 2026: Transfer Pricing Amendments Under Finance Act, 2026 Come Into Force[52]

Following the gazetting of the Finance Act 2026, several transfer pricing amendments formally took effect on April 01, 2026. These include the implementation of the block transfer pricing assessment framework, rationalization of safe harbor rates for IT services, procedural changes to the Advance Pricing Agreement (APA) regime, such as reduced application fees for specified taxpayers, faster timelines for eligible cases, and rationalized annual compliance reporting; and enabling provisions allowing non-resident associated enterprises to file modified returns to give effect to corresponding adjustments. The changes mark a shift toward greater certainty, procedural efficiency, and streamlined dispute resolution in India’s transfer pricing regime.

March 31, 2026:CBDT Achieves Record Milestone Under Advance Pricing Agreement Program[53]

The CBDT reported a record performance under India’s APA program, concluding 219 APAs during FY 2025-26, comprising both Unilateral and Bilateral APAs. With this, the cumulative number of APAs since the inception of the program has crossed the 1,000th milestone, aggregating to 1,034 APAs, including 750 unilateral and 284 bilateral agreements. The year also marked the highest ever number of bilateral APAs signed in a single financial year, with 84 BAPAs concluded pursuant to mutual agreement procedures with 13 treaty partners, including the United States, the United Kingdom, Japan, Singapore, and Australia. Notably, FY 2025-26 witnessed the signing of India’s first-ever bilateral APAs with France, Ireland, Indonesia, and Sweden.

Malaysia

March 18, 2026: Malaysia Sets Out Revised Taxation for REIT and PTF Investors[54]

The Inland Revenue Board of Malaysia has released guidance outlining changes to the tax treatment of distributions made by real estate investment trusts (REITs) and property trust funds (PTFs), with effect from the year of assessment (YA) 2026. From that year, the preferential 10% withholding tax previously applied to certain unitholders, including individuals and foreign institutional investors, will be replaced. Instead, resident unitholders will be taxed on distributions at their applicable income tax rates without any withholding, while non-resident companies will continue to be subject to a final withholding tax of 24%. Other non-resident unitholders (including individuals and foreign institutional investors) will no longer be subject to withholding tax but must report such income in their respective tax returns. The Practice Note also reiterates that, for YAs 2020 to 2025, a 10% withholding tax applied to most non-corporate unit holders, with non-resident companies remaining subject to a 24% rate.

Singapore

March 06, 2026:Singapore Expands CbCR List[55]

On March 06, 2026, the Inland Revenue Authority of Singapore (IRAS) revised the jurisdictions covered under Singapore’s framework for the automatic exchange of CbC reports pursuant to the Multilateral Competent Authority Agreement on Automatic Exchange of CbC Reports (CbC MCAA). The revision brings Mongolia, Serbia, and Vietnam into scope for financial years commencing on or after December 01, 2023, adds Montenegro for financial years beginning on or after January 01, 2024, and includes Armenia for financial years starting on or after January 01, 2025.

Vietnam

March 12, 2026: Vietnam Provides Clarity on Corporate Income Tax Framework[56]

On March 12, 2026, Vietnam’s Ministry of Finance released a new circular (Circular 20/2026) on corporate income tax (CIT). Circular 20/2026 provides various guidance inter alia documentation requirements for supporting tax deductions, corporate income tax incentives, and rules on revenue recognition and the taxation of foreign contractors including e-commerce and digital platform-based businesses. Notably, it also clarifies several points on capital transfer tax (CTT) for foreign transferors e.g., the taxing point and several requirements/conditions for CTT exempted internal restructurings.

Japan

March 31, 2026: Japan Enacts Various Tax Reform Bills[57]

Japan has announced significant enhancements to its tax incentive framework, including a large‑scale capital investment incentive offering immediate depreciation and tax credits of up to 7% across all industries. R&D incentives are being strengthened through the introduction of a new ‘strategic technology’ category (including AI and quantum technologies), alongside tighter conditions to promote domestic R&D activity. The reforms also provide for the introduction of the OECD’s Pillar Two Side‑by‑Side Package from January 2026 (excluding the simplified ETR safe harbor), and revisions to the special tax rules for foreign partners in partnerships, including an increase in the ownership threshold for fund interests, aimed at supporting inbound investment while ensuring appropriate tax treatment.

Thailand

March 19, 2026:Thailand Clarifies Procedures for Reduced Corporate Income Tax Regime in SEZs[58]

On March 19, 2026, Thailand’s Revenue Department issued Notification No. 468, setting out the procedural rules for companies and juristic partnerships seeking to apply the reduced corporate income tax rate for activities carried out in Special Economic Zones (SEZs). The notification prescribes filing requirements to claim the incentive, clarifies that income and expenses relating to SEZ and non-SEZ activities must be computed separately, and requires proportional allocation of shared expenses based on revenue. Any tax losses are ring‑fenced to the specific activity that generates them and cannot be offset across activities. The notification applies from June 06, 2025.

Bahrain

March 11, 2026: NBR Issues Updated Imports and Exports VAT Guide[59]

The Bahrain National Bureau for Revenue (NBR) has issued an updated version of the Imports and Exports VAT Guide, which introduces targeted clarifications to the VAT treatment of cross-border transactions. The update notably includes a new section addressing the VAT implications where tax is paid as a deposit in import or export scenarios, providing additional guidance on the treatment and recoverability of such amounts. The guide also consolidates existing principles on the application of VAT to imports and exports, reaffirming documentation and compliance expectations for taxpayers engaged in international trade.

Oman

March 18, 2026: Oman to Implement “Fawtara” E‑Invoicing Platform in Phases from August 01, 2026[60]

The Oman Tax Authority has initiated the phased rollout of its new “Fawtara” electronic invoicing platform. Beginning in August 2026, the first phase will apply to 100 large VAT‑registered taxpayers, followed by all large taxpayers in February 2027, and the remaining VAT‑registered entities in August 2027. The centralized platform adopts a five‑corner model for the secure exchange of invoice data between businesses, service providers, and the Tax Authority. As implementation progresses, affected taxpayers will be required to issue invoices in an approved electronic format, utilize authorized service providers, or compatible enterprise resource planning systems, and ensure timely submission of invoice information to the authorities to meet compliance obligations.

Qatar

March 16, 2026: Qatar Permits Treaty Withholding Tax Application at Source[61]

Qatar has amended the executive regulations under its Income Tax Law through the Council of Ministers Decision No. 4 of 2026, allowing the direct application of beneficial treaty withholding tax rates without requiring a post‑withholding refund claim by non‑resident recipients. Under the revised framework, only entities granted Approved Debtor status by the General Tax Authority may apply treaty provisions at source, subject to verification that the recipient is a treaty resident, the beneficial owner of the relevant income, and that the payment is neither attributable to a permanent establishment in Qatar nor part of an arrangement primarily intended to obtain treaty benefits. Eligible requests must be supported by appropriate documentation and will be reviewed by the Approved Debtor within 60 days, after which the request is deemed rejected if no decision is issued.

March 29, 2026: Tax‑Neutral Corporate Restructuring Regime Enters Into Force[62]

In March 2026, Qatar brought into force a tax‑neutral corporate restructuring regime pursuant to the Council of Ministers Decision No. (3) of 2026, as announced by the General Tax Authority (GTA), under which capital gains arising from qualifying mergers, demergers, and intragroup transfers may be exempt from income tax, provided the transactions are undertaken for a genuine economic, commercial, or financial purpose and comply with prescribed substance, ownership, continuity and anti‑avoidance conditions under the Income Tax Law and its Executive Regulations; the measure aims to facilitate intra‑group reorganizations, improve capital allocation efficiency and support market‑driven restructuring activities, including preparatory steps for listings, without triggering immediate tax leakage.

United Arab Emirates (UAE)

March 18, 2026: UAE Launches R&D Tax Credit with Detailed Eligibility Rules[63]

The UAE Ministry of Finance has introduced a non-refundable research & development (R&D) tax credit under Phase 1 of its Tax Incentives Program, alongside Ministerial Decision No. 24 of 2026, which sets out detailed eligibility conditions. The regime provides credits of 15%, 35%, or up to 50% on qualifying expenditure capped at AED 5 million, applicable from January 01, 2026, and subject to minimum spend, and UAE-based R&D staffing requirements. Eligible activities must be conducted locally and meet criteria aligned with the OECD Frascati Manual, with mandatory pre-approval of projects. The rules also cover qualifying costs, documentation, carry forward or transfer of unused credits, and anti-abuse provisions.

March 29, 2026: UAE Approves OECD Crypto‑Asset Reporting Framework Agreement[64]

During its meeting on March 29, 2026, the UAE Cabinet of Ministers approved the Multilateral Competent Authority Agreement on the Automatic Exchange of Information pursuant to the Crypto‑Asset Reporting Framework. It establishes a standardized framework for the reporting of tax‑relevant information on crypto‑asset transactions, enabling the automatic exchange of such information.

March 15, 2026: Dubai Customs Activates UAE–Oman Green Corridor to Facilitate Cargo Movement[65]

Dubai Customs has activated a Green Corridor, enabling goods arriving at Omani seaports to be transported to Dubai under customs duty suspension, via the Al Wajajah border crossing to the Hatta Customs Centre. Goods destined for the UAE domestic market may be cleared at Hatta, while goods intended for Dubai ports or free zones are subject to separate customs procedures. The corridor operates under customs supervision, with duties and formal import clearance deferred to the point of final destination in Dubai. The arrangement also applies in reverse, supporting export flows from Dubai via Oman’s seaports. The measure applies across most goods categories, subject to specific exclusions.

March 31, 2026: Dubai Customs Extends Transit Period and Introduces Additional Facilitation Measures[66]

Dubai Customs has issued Notice CN5/2026, extending the permitted transit period from 30 days to 90 days for goods moving under transit procedures, including the submission of supporting documentation required to discharge transit declarations. The extension replaces the previous timeline and allows for further extensions, subject to approval. In parallel, Notice CN6/2026 introduces additional facilitation measures, including temporary arrangements allowing cargo arriving through Khorfakkan and Fujairah ports to be transported under bonded movement to Jebel Ali Port and Dubai free zones for customs clearance. These measures are intended to support alternative routing options and mitigate delays arising from ongoing regional logistics disruptions, while maintaining existing customs control and compliance requirements.

Australia

March 12, 2026: ATO Publishes Further Guidance on Implementation of Pillar Two[67]

On March 12, 2026, the Australian Taxation Office (ATO) issued further guidance on Australia’s Pillar Two minimum tax regime. The guidance confirms the application of the Income Inclusion Rule and Domestic Minimum Tax (DMT) from income years beginning on or after January 01, 2024, with the Undertaxed Profits Rule (UTPR) applying from January 01, 2025, for multinational groups meeting the EUR 750 million revenue threshold. It also clarifies the interaction of Pillar Two with Australia’s tax consolidation regime, including the identification of constituent entities, allocation of top‑up tax, and intra‑group adjustments, as well as the treatment of complex structures such as joint arrangements, permanent establishments, flow‑through and dual‑resident entities. In addition, the guidance addresses the treatment of foreign tax credits and post‑filing tax adjustments, incorporates OECD safe harbor provisions, and outlines expanded filing requirements, underscoring the importance of data, systems and governance readiness ahead of initial compliance.

March 19, 2026: PepsiCo High Court Decision: ATO Seeks To Limit Broader Application[68]

In August 2025, the High Court in Commissioner of Taxation v. PepsiCo Inc., held that payments made by Australian bottlers for beverage concentrate did not include any embedded royalty and therefore, did not attract royalty withholding tax or diverted profits tax. Following the High Court decision, the ATO issued a Decision Impact Statement on March 19, 2026, that seeks to confine the ruling to its facts. The ATO emphasizes that the outcome depended on exceptional circumstances, including arm’s length dealings with an unrelated bottler, consistent global commercial practices, and evidence that concentrate pricing did not reflect any Intellectual Property related premium. It provides that the PepsiCo structure is not representative of typical multinational arrangements involving significant intangibles and that the compliance stance on embedded royalties, restructuring eliminating royalty streams, and royalty based alternative scenarios in diverted profits tax cases remain unchanged.

March 25, 2026: Australia Clarifies Pillar Two Implications of Group Restructuring[69]

On March 25, 2026, the ATO released guidance explaining how group restructuring and transition‑year rules affect Pillar Two outcomes for tax‑consolidated groups. The guidance clarifies the determination of key GloBE attributes, such as deferred tax assets and liabilities, asset carrying values and GloBE income, following acquisitions, internal reorganizations and other structural changes. It sets out the application of transition and integrity rules, including baseline and asset transfer integrity measures, ownership-interest transfers, deemed asset and liability transfers, and the fair-value adjustment election, supported by practical examples, including the treatment of transactions occurring before December 01, 2021.

New Zealand

March 19, 2026: New Zealand Refines August 2025 Tax Bill With Targeted Amendments [70]

New Zealand’s Minister of Revenue released an Amendment Paper on March 19, 2026, proposing targeted refinements to the August 2025 tax bill. Key measures include aligning the application of OECD GloBE guidance with OECD-specified dates and introducing an elective interest-deductibility regime, without a thin capitalization adjustment, for eligible infrastructure entities from the 2026-27 income year. The amendments also allow certain Crown investment entities to move from provisional to annual income tax payments, expand Inland Revenue’s ability to share unpaid tax information with credit agencies, clarify expense deductibility and GST eligibility for contractors following recent employment law changes, and confirm the offset of GST bad‑debt claims by insolvency practitioners against pre‑appointment tax liabilities, with retrospective effect.

March 27, 2026: New Zealand Sets Out Proposed Approach to Tax Debt Relief [71]

On March 27, 2026, New Zealand Inland Revenue released draft guidance for consultation, setting out how it considers requests for relief from tax debt under the Tax Administration Act 1994. The draft explains the circumstances in which Inland Revenue may write off tax, interest, or penalties, remit charges, agree on payment instalment arrangements, or defer recovery action, even where the tax has been correctly assessed. It also outlines the types of debts and situations that may qualify for relief, the forms of relief available, and the legislative factors Inland Revenue must consider, including whether providing relief would result in a better overall collection outcome over time than pursuing immediate recovery. The consultation period remains open until May 08, 2026.

• On March 1, 2026, Ukraine ratified the Comprehensive Economic Partnership Agreement with the United Arab Emirates, following its signing on February 17, 2025. The agreement aims to enhance bilateral trade and investment relations, with further developments expected as implementation progresses.[72]
• On March 04, 2026, the US Court of International Trade (CIT) in Atmus Filtration, Inc. v. United States, ordered US Customs and Border Protection (CBP) to remove unlawful tariffs imposed under the International Emergency Economic Powers Act (IEEPA). Implementing the US Supreme Court’s February 2026 ruling, the CIT established a clear refund pathway by directing CBP to eliminate IEEPA tariffs from both unliquidated entries and recently liquidated entries still within the statutory reopening period. The court further clarified that this relief applies to all affected importers, not only those that brought legal challenges, and requires duties to be recalculated as if the IEEPA tariffs had never applied. [73]
• On March 11, 2026, the US Trade Representative (USTR) initiated Section 301 investigations into whether the European Union and 15 other economies across Europe and Asia maintain policies related to structural excess capacity in manufacturing that burden US commerce. Consultations with the affected governments have been requested; the public comment period opened on March 17, 2026, written submissions and hearing requests were due by April 15, 2026, and public hearings are scheduled to begin on May 05, 2026. If the investigations yield affirmative findings, the USTR may consider tariff and non‑tariff measures, signaling a move toward established trade enforcement tools following the invalidation of IEEPA based tariffs.[74]
• Following the US Supreme Court’s decision invalidating tariffs imposed under the IEEPA, CBP on March 12, 2026, informed the CIT that it is developing a dedicated mechanism to administer duty refunds. In the filings done in the case of Atmus Filtration, Inc. v. United States, CBP explained that it is building a new capability within the Automated Commercial Environment (ACE), known as the Consolidated Administration and Processing of Entries (CAPE), to calculate and process refunds. It will enable electronic claim submission, bulk validation, and automated liquidation or reliquidation of entries.[75]
• On March 24, 2026, Australia and the European Union (EU) announced that they finalized negotiations on a bilateral Free Trade Agreement (FTA), concluding talks that began in July 2018. Subject to signature and entry into force, the agreement is expected to substantially ease market access by removing the majority of Australian tariffs on EU-origin goods and enabling duty-free treatment for approximately 98% of the current value of Australian exports to the EU. It also includes provisions aimed at facilitating trade in areas central to the energy transition, particularly critical minerals and hydrogen. In addition, the deal incorporates enforceable trade and sustainable development obligations, spanning labor standards, gender equality, environmental protections, Paris Climate Agreement related commitments, a focus on sustainable food systems, and enhanced liberalization for green goods and services.[76]