With the first GloBE Information Return (GIR) filing due by June 30, 2026, for in‑scope multinational enterprise (MNE) groups[1] with a December 31, 2024, fiscal year (FY) end, the focus is shifting from planning to the practical execution of Pillar Two compliance obligations. MNE groups are now focusing on the operational workstreams required for filing the GIR, including data collection, systems configuration, and readiness for submission and information exchange across Pillar Two implementing jurisdictions.

On May 18, 2026, the OECD released a “common understanding”[2] reflecting agreement among implementing jurisdictions aimed at supporting centralized GIR filing and exchange for FY2024. This update recognizes potential first-year operational constraints, including delays in the availability of GIR filing portals and the activation of exchange relationships, and sets out a coordinated administrative approach to preserve the intended benefits of centralized GIR filing for FY2024 returns.

The GIR is a standardized information return required under Article 8.1 of the Global Anti-Base Erosion (GloBE) Rules issued by the OECD Inclusive Framework on Base Erosion and Profit Shifting (BEPS). The GIR must be filed no later than 15 months after the end of the reporting FY, extended to 18 months for the transitional year. The OECD Administrative Guidance specifies that no GIR filing or notification obligation may fall due before June 30, 2026.

The GIR was introduced to establish a single, standardized compliance framework, reducing the need for fragmented jurisdiction-specific filings while providing tax administrations with a consistent basis for risk assessment and verification. It supports tax authorities in assessing and verifying an MNE group’s top‑up tax position and serves as the operative basis for the automatic exchange of GloBE information between tax administrations globally.

Following its initial release in July 2023, the GIR framework was materially strengthened by the OECD’s January 2025 package, which transformed the GIR into an operational compliance infrastructure through: (i) a revised GIR template[3], (ii) targeted Administrative Guidance on completion methodology[4], (iii) the GIR Multilateral Competent Authority Agreement (MCAA)[5] supporting automatic exchange, and (iv) a standardized XML Schema[6] updated in July 2025, and user guide to facilitate structured reporting. 

GIR Structure and Transitional Simplified Jurisdictional Reporting Framework

Where an MNE group elects to file a GIR in a particular jurisdiction, the filing will include Section 1 (MNE Group Information) and Section 2 (Jurisdictional Safe Harbours and Exclusions) in all cases, together with Section 3 (GloBE Computations), where applicable.

During the transitional period, i.e., FYs beginning on or before December 31, 2028, but not including an FY that ends after June 20, 2030, MNE groups may complete Section 3 (GloBE Computations) on a jurisdictional basis rather than on a CE-by-CE basis under the transitional simplified jurisdictional reporting framework (transitional framework). The purpose of this transitional framework is to provide in‑scope MNE groups with additional time to develop accounting systems, IT infrastructure, and internal processes necessary to support full CE‑by‑CE reporting for GloBE purposes.

Under the transitional framework, jurisdictional level reporting may be applied, on an elective basis, only for jurisdictions where:

• No Top‑up Tax liability arises; or
• A Top‑up Tax liability arises, but it does not need to be allocated on a CE-by-CE basis.

However, the transitional framework does not apply to jurisdictions where a Top‑up Tax liability arises and it must be allocated on a CE-by-CE basis. For those jurisdictions, MNE groups are required to complete Section 3 with full CE-level detail, including separate reporting of additions and reductions for each relevant GloBE adjustment. Section 3 must also be completed for jurisdictions that do not qualify for applicable safe harbors, such as the Transitional CbCR Safe Harbor, even where the resulting GloBE calculations give rise to no Top‑up Tax liability. 

While the transitional framework allows for jurisdictional-level reporting in the GIR, it does not modify the underlying mechanics of the GloBE Rules. Where a specific provision of the GloBE Rules requires a calculation to be performed at the CE-level, that calculation must still be undertaken on a CE‑by‑CE basis, even if the resulting information is reported in aggregated form in the GIR. Tax administrations retain full right to request additional CE-level information through follow-up information requests as part of their normal compliance and risk assessment procedures.

Dissemination of GloBE Information: Central Filing vs Local Filing

Under Article 8.1.1 of the GloBE Rules, local filing is the default position, requiring each CE of an in-scope MNE Group located in an implementing jurisdiction to file a GIR in their respective jurisdiction. Where several CEs are located in the same jurisdiction, the MNE Group has an option to appoint a Designated Local Entity (DLE) to submit the GIR on behalf of the other CEs in the same jurisdiction.

Article 8.1.2 of the GloBE Rules provides a central filing carve‑out under which a CE is relieved from local filing if the GIR is filed by the Ultimate Parent Entity (UPE) or a Designated Filing Entity (DFE) in its jurisdiction of residence, provided a Qualifying Competent Authority Agreement (QCAA) is in effect at the time of filing to enable the exchange of GIR information with the jurisdiction of the CE.

The GIR MCAA establishes the multilateral legal framework under which QCAAs arise and enables the automatic exchange of GIRs between jurisdictions. While the signature of the GIR MCAA is a necessary precondition, the ability to rely on central filing depends on whether the relevant bilateral exchange relationship between the jurisdictions has been activated.

As of May 2026, the OECD has published an updated list confirming that 32 jurisdictions have signed the GIR MCAA[7], including major implementing jurisdictions such as the United Kingdom, France, Germany, and Japan. According to the OECD’s Automatic Exchange of Information (AEOI) portal[8], approximately 700 bilateral exchange relationships were activated as of April 24, 2026, indicating that the GIR exchange network is already operational at scale. The jurisdiction receiving the centrally filed GIR is entitled to the complete set of GIR information and acts as the exchange hub for disseminating relevant data to other Pillar Two-implementing jurisdictions. The exchange of GloBE information is governed by a targeted dissemination approach, under which GIR information is shared with other jurisdictions only to the extent that they have taxing rights under the GloBE rule order. The CE must notify its local tax administration of the identity and location of the UPE or DFE filing the GIR. This is a separate obligation from the GIR itself and precedes the filing deadline in several jurisdictions. 

The OECD’s May 2026 common understanding nevertheless recognizes that some jurisdictions may face timing gaps in making GIR filing portals fully operational or in activating exchange relationships before the first GIR filing deadline. For these first-year circumstances, the participating jurisdictions have agreed to use mechanisms available under domestic law to preserve the administrative and compliance benefits of central filing, including waiving penalties or refraining from enforcing local GIR filing obligations before the relevant exchange deadline, where:

• The GIR has been centrally filed in one of the jurisdictions that are operationally ready to support central filing[9] by June 30, 2026.
• The relevant local notification requirements have been satisfied.

However, not all jurisdictions have joined this approach, the Bahamas, North Macedonia, the Slovak Republic, and Vietnam have not signed on to the common understanding as of May 2026, and Greece and Poland are offering relief only for central filings made in an EU Member State. MNE groups operating in these non-participating jurisdictions should therefore plan to file the GIR locally or ensure bilateral exchange relationships are active by the filing due date, i.e., June 30, 2026.

GIR Updates: A Cross-Jurisdictional Overview

Tax authorities across major jurisdictions have been actively issuing guidance and regulations to implement GIR obligations under Pillar Two, reflecting broad convergence around the OECD’s framework. As jurisdictions prepare for initial adoption and ongoing compliance, tax authorities are aligning their data standards, filing mechanics, and exchange frameworks with the OECD’s model to promote consistency and enable the effective, automatic exchange of information under the GloBE regime. 

In several jurisdictions, GIR filing has been integrated into domestic Pillar Two compliance frameworks. For instance, the United Kingdom has embedded GIR filing within its domestic regime, generally requiring in‑scope groups either to submit a GIR locally or to notify the tax authority of where a return has been filed in another jurisdiction pursuant to a QCAA.

Australia’s implementation follows a similar path, aligning with the OECD’s Pillar Two framework. The Australian Taxation Office (ATO) has mandated that in-scope MNE groups must lodge a GIR either locally with the ATO or, if a GIR is filed overseas by a designated entity under a QCAA, submit a local foreign lodgment notification instead.

Japan has similarly issued supplementary administrative guidance closely aligned with the OECD’s standardized GIR template. The Japanese framework places emphasis on electronic filing and adherence to the OECD XML schema, reinforcing consistency in reporting formats and facilitating cross‑border information exchange. This approach reflects a broader trend among early moving jurisdictions to minimize deviations from the OECD’s prescribed reporting architecture.

Key Takeaways for MNE Groups

Given that first-year GIR filings are due as early as June 30, 2026, central filing is emerging as a viable compliance approach for many MNE groups, but only where specific conditions are met. 

MNE groups should assess central versus local GIR filing on a jurisdiction‑by‑jurisdiction basis. This requires identifying the appropriate filing entity, confirming the participation of the filing jurisdiction in the GIR MCAA, and verifying that the relevant bilateral exchange relationships with constituent-entity jurisdictions are operational. 

MNEs need to determine whether each jurisdiction where they operate is covered by the common understanding on central-filing relief, and plan to file locally where relief or exchange coverage is not yet active. MNE groups should note that any relief from penalties or deferral of local GIR-filing obligations applies only to the extent permitted under domestic law. MNE groups should, therefore, take domestic law requirements into account alongside OECD guidance when determining their GIR-filing approach.

Given the scale and technical complexity of the GIR, reliance on manual preparation is unlikely to be sustainable beyond the simplest organizational structures. MNE groups are, therefore, increasingly expected to deploy fit‑for‑purpose Pillar Two technology solutions capable of supporting data integration, GloBE adjustments, calculation engines, and jurisdiction‑specific filing requirements, including XML‑based reporting outputs.

Finally, the GIR implementation landscape remains dynamic as jurisdictions continue to operationalize the GloBE framework through evolving administrative practices, domestic guidance, and information exchange arrangements. Ongoing monitoring of OECD guidance, QCAAs, and local legislative changes remains essential to maintaining technical compliance and ensuring that GIR-filing strategies remain aligned with the Pillar Two framework.

USA

April 17, 2026: Proposed US Rules Update on Gambling Loss Deductions and Reporting Thresholds[10]

The Department of the Treasury and the Internal Revenue Service (IRS) released proposed regulations implementing certain amendments introduced under the One Big Beautiful Bill Act (OBBBA). The proposals address statutory changes that would limit wagering-loss deductions to 90% of total losses, without exceeding gambling gains, for tax years beginning after December 31, 2025. They would also address the increase in the information-reporting threshold from $600 to $2,000 for payments made on or after January 01, 2026, with inflation adjustments starting in 2027, and would standardize gambling winnings reporting thresholds at $2,000 from 2026 onwards.

April 21, 2026: Tenth Circuit Applies Economic Substance Doctrine Without Separate Relevancy Inquiry[11]

The US Court of Appeals for the Tenth Circuit, in a two to one decision, affirmed the district court in Liberty Global Inc. v. United States, No. 23-1410, concluding that a four-step internal restructuring among foreign affiliates lacked economic substance and could not support a dividends-received deduction under §245A. The restructuring was designed to take advantage of a “last day” mismatch in international tax provisions enacted by the Tax Cuts and Jobs Act, thereby avoiding GILTI and Subpart F inclusions while preserving §245A eligibility. The court applied the economic substance doctrine to the integrated transaction as a whole, without requiring a separate threshold inquiry into the doctrine’s relevance. In doing so, the court denied tax benefits it found inconsistent with congressional intent, despite literal compliance with the statutory provisions, potentially complicating planning for certain multi-step transactions. This approach contrasts with the Tax Court’s decision in Patel v. Commissioner, 165 T.C. 10 (2025), in which the court first considered whether the economic substance doctrine was relevant to the transaction at issue, before concluding that the micro-captive insurance arrangements lacked economic substance.

Canada

April 01, 2026: Canadian Tax Amendments Under Bill C-15 Enacted into Law[12]

Canada enacts significant changes to transfer pricing (TP) rules, repeals the digital services tax (DST), and expands business tax incentives under Bill C-15, effective March 26, 2026. The TP measures apply to taxation years beginning after November 04, 2025, introducing a revised delineation framework, closer alignment with the OECD TP Guidelines, and enhanced documentation requirements. The DST repeal is effective from June 20, 2024, eliminating the 3% tax and enabling refunds of amounts paid, with interest. Scientific research and experimental development incentives apply to taxation years beginning on or after December 16, 2024, including an increased expenditure limit and expanded eligibility. Investment measures confirm accelerated allowances and up-front cost deduction for eligible property acquired on or after January 01, 2025. Clean-economy incentives, including tax credits, are extended and expanded through 2035. The provisions largely reflect earlier proposals, with no significant changes to the core tax measures.

Belgium

April 03, 2026: Extended Filing Deadlines Introduced for Belgium’s DMTT and IIR Regime[13]

Belgium’s Federal Public Service Finance has extended the filing deadline for both the Qualified Domestic Minimum Top-Up Tax (QDMTT) and the Income Inclusion Rule (IIR) Top-up Tax to September 30, 2026, for all reporting periods that would otherwise have fallen due earlier. Specifically, this covers QDMTT returns for years beginning on or after December 31, 2023, and ending between January 01, 2024, and September 30, 2025, as well as IIR returns for periods beginning between December 31, 2023, and December 31, 2024, (ending by February 28, 2025) or beginning on or after January 01, 2025, and ending by May 31, 2025. Taxpayers should await forthcoming instructions and technical documents related to the declaration procedures.

April 17, 2026: Belgium Proposes Digital Services Tax From 2027[14]

Belgium’s Lower House is considering a proposal to introduce a Digital Services Tax (DST), effective from January 01, 2027. The bill, submitted by an opposition party, targets multinational enterprises with globally consolidated revenues exceeding EUR 750 million, and domestic revenues in Belgium above EUR 3 million. The proposed DST would be levied at 3% on revenues from specified digital activities, including online advertising, digital intermediation services, and the use or sale of data generated by Belgian users. Taxpayers would be required to file DST declarations and settle the liability within three months after the close of the financial year.

April 21, 2026: Belgium Rolls Out New Tax Measures on Shares and Crypto[15]

Belgium has passed a new law taxing capital gains on shares and cryptocurrencies at rates between 1.25% and 10%. It also introduces a 10% withholding tax on certain financial instruments and insurance products, with effect from January 01, 2026, on a retroactive basis. The legislation was published in the Official Gazette on April 21, 2026.

France

April 15, 2026: Tax Authorities Revamp MAP and APA Guidelines[16]

Following a public consultation held between January 15, 2025, and March 01, 2025, the tax authorities issued revised guidance on April 15, 2026, covering Mutual Agreement Procedures (MAP) and Advance Pricing Arrangements (APA). The update clarifies the meaning of an administrative measure that may result in treaty-inconsistent taxation, explains the conditions under which taxpayers can seek MAP relief for transfer pricing matters through an amended return, and specifies the circumstances that allow the retroactive application of an APA.

April 22, 2026: France ReleasesAdministrative Guidance on Withholding Tax Claim Limitation Period[17]

On April 22, 2026, the tax authorities issued updated administrative guidance on claim deadlines following a February 16, 2026 decision of the French Administrative Supreme Court. The Court held that the shorter limitation period for withholding tax refund claims (previously, December 31 of the year following the withholding) is incompatible with the principle of equality, as similar income taxes benefit from a longer deadline (December 31 of the second year following payment of the tax). While the government has been instructed to introduce revised rules within three months of notification of this decision, no measures have been announced to date. Pending these changes, taxpayers subject to withholding tax in 2024 may be able to file claims up to December 31, 2026.

Finland

April 22, 2026: Government Outlines New Corporate and Individual Tax Measures[18]

On April 22, 2026, the government announced the outcome of its mid-term budget discussions, outlining several tax measures. On the corporate side, it reaffirmed plans to reduce the corporate income tax rate from 20% to 18%, effective January 01, 2027. For individuals, the key measures include increasing the household services tax credit from 35% to 40% and raising the annual cap from EUR 1,600 to EUR 2,100 (intended to take effect in 2026); lowering the commuting-expense deduction threshold from EUR 900 to EUR 800; and revising stock option taxation so that gains from non-listed companies are taxed upon sale rather than at exercise. Additional measures include expanding employee share schemes to cover subsidiary employees; broadening donation deductions to include donations to health and social welfare organizations; indexing the EUR 400 cap on employer‑provided recreational vouchers for inflation, and expanding its scope to include hunting and fishing; and increasing the entrepreneur deduction from 5% to 5.5%.

April 28, 2026: Finland Adopts OECD Approach for Attributing Profits To Permanent Establishments[19]

On April 28, 2026, legislation was gazetted to update the rules on attributing profits to Permanent Establishments (PEs), formally adopting the authorized OECD approach (AOA) into domestic law. The changes, enacted through amendments to the Income Tax Law, the Business Income Tax Law, and the Law on the Elimination of International Double Taxation, will apply from January 01, 2027, and align Finland’s PE profit attribution framework with OECD standards.

Italy

April 01, 2026: Italy Updates Operating Rules for the CFC "Effective Taxation" Election[20]

Following the amendments introduced by Article 4 of Decree-Law No. 84/2025, converted by Law No. 108/2025, the payment of an amount equal to 15% of the controlled foreign entity’s net accounting profit no longer operates as a stand-alone substitute tax. Rather, it functions as an optional deemed-compliance mechanism, or safe harbour: where the Italian controlling entity makes such payment, the effective taxation of the foreign-controlled entity is deemed not to be lower than 15%, thereby preventing the low-taxation condition under Article 167, paragraph 4, letter a), of the Italian Income Tax Code from being met.

The implementing measure issued by the Italian Revenue Agency governs the election and revocation mechanics, the relevant tax base, the three-year duration and renewal of the option, and the payment terms, which are aligned with those applicable to income taxes. The mechanism is intended to reduce uncertainty and compliance burdens for groups with foreign controlled entities potentially falling within the CFC regime.

April 22, 2026: Italy Advances Consolidated Framework for Tax Compliance and Assessments[21]

The Council of Ministers, at session No. 170 held on April 22, 2026, granted preliminary approval to a draft legislative decree establishing the Consolidated Code of legislative provisions on tax obligations and tax assessment, adopted to implement the tax-reform delegation under Law No. 111/2023. The draft decree is intended to identify, reorganise, and coordinate existing provisions by homogeneous subject matter, while expressly repealing incompatible or obsolete rules. It is structured into three parts: Part I (Tax Obligations) covers the tax registry, fiscal code, accounting and record-keeping requirements, income tax and VAT filing obligations, synthetic tax-reliability indices (ISA), periodic settlements, and digital simplification; Part II (Cooperation, Controls and Assessment) consolidates the rules on cooperative compliance, the biennial preventive agreement (concordato preventivo biennale), advance rulings for new investments, dispute-resolution mechanisms, assessment procedures, including assessment with adhesion, as well as the powers of the tax administration and the automatic exchange of information; Part III contains transitional and final provisions. Following parliamentary review and final approval by the government, the provisions are expected to apply from January 01, 2027.

April 22, 2026: Italy Approves Application Form for IRAP Refund and Compensation on Intra-EU/EEA Dividends[22]

The Italian Revenue Agency, with Provision No. 123184 of April 22, 2026, approved the application form and implementing rules for the refund or use-in-compensation of the portion of IRAP attributable to intra-EU or EEA dividends that contributed to the net-production value above 5%. The measure implements Article 1, paragraphs 48 and 49, of the 2026 Budget Law (Law No. 199/2025), which aligned the Italian IRAP regime with the CJEU judgment of August 01, 2025 (Joined Cases C-92/24 to C-94/24, Banca Mediolanum), and with Article 4 of the Parent-Subsidiary Directive (2011/96/EU). For fiscal years in progress on December 31, 2025, and onwards, qualifying intra-EU/EEA dividends are excluded from the IRAP net-production value for 95% of their amount under Articles 6 and 7 of Legislative Decree No. 446/1997 – provisions specifically applicable to financial intermediaries (e.g., banks and SIMs) and insurance companies. For prior fiscal years that are still within the 48-month time limit under Article 38 of Presidential Decree No. 602/1973, taxpayers may claim a refund through the newly-approved form; alternatively, they may elect to use the amount in compensation via Form F24, exclusively for payment of the extraordinary banking contribution under Article 1, paragraphs 68-73, of the 2026 Budget Law. Where the 48-month time limit expires within 60 days of publication of the Provision (i.e., by June 21, 2026), the application may be filed by that special deadline. The measure is potentially relevant for Italian banks, other financial intermediaries, and insurance companies that historically included more than 5% of qualifying EU/EEA dividends in their IRAP base.

Netherlands

April 01, 2026: Public Consultation on Tax Incentives for Startups and Scale-Ups[23]

The Dutch Ministry of Finance has launched a public consultation covering a legislative proposal to strengthen the Netherlands' attractiveness for innovative companies by revising the tax treatment of employee equity participation and investments in startups and scale-ups. A key element is a new payroll-tax regime for share options granted by qualifying startups and scale-ups to their employees, under which only 65% of the income from these options would be taxable, and taxation would generally be deferred until the actual sale of the shares. The proposal also sets out the key criteria to qualify as a startup and scale-up, and the consequences where companies grow out of the startup or scale-up phase. The proposal further clarifies that shares in startups and scale-ups would be taxed in Box 3 of the Dutch personal income tax regime upon disposal, aligning the Box 3 taxation more closely with the often-illiquid nature of these shares.

April 01, 2026: Impact of the Earnings Stripping Rule on (Real Estate) Investments[24]

The Ministry of the Interior announced that it will further examine the impact of the earnings stripping rule (ESR) on the real estate sector, given the decline in (foreign) investments in residential real estate. The Dutch ESR was implemented as part of the mandatory tax measures under the EU Anti-Tax Avoidance Directive (ATAD). The ESR, shortly put, caps the deductibility of (net) interest expenses for Dutch corporate income tax purposes at the higher of: (1) 24.5% of tax-based EBITDA, or (2) € 1 million. Excess interest is non-deductible in the relevant fiscal year, although it can generally be carried forward. The Netherlands has not implemented the ATAD’s group-ratio escape, which would in theory have allowed third-party interest to remain deductible. This makes the Dutch implementation of the earnings stripping rule particularly strict. Moreover, the Netherlands implemented 24.5%/€ 1 million limits, instead of ATAD’s standard 30%/€ 3 million limits. Given rising interest rates in recent years, an increasing number of Dutch corporate taxpayers have been hit by non-deductible third-party interest under the Dutch ESR. For this reason, Dutch social-housing corporations and commercial real estate investors are taking the Dutch tax authorities to court. Also, investors outside the real estate industry are following suit.

April 01, 2026: Update on Tax Exemptions for Foreign Pension Funds[25]

The Dutch Ministry of Finance responded to parliamentary questions about the decline in investments by foreign pension funds in Dutch residential real estate. The ministry indicated that the Dutch tax authorities will reassess whether the 12 cumulative criteria for a foreign pension fund to qualify for the Dutch corporate income tax (CIT) and dividend withholding tax exemptions require amendment. The ministry also confirmed that amending these criteria would not necessarily require parliamentary approval given that they are set out in a decree, provided any amendments do not conflict with the exemptions in the Dutch CIT Act and Dividend Tax Act. The Ministry reiterated that introducing a new Dutch REIT regime is still not on the policy agenda.

April 17, 2026: Public Consultation on Dividend Stripping Measures[26]

The Dutch Ministry of Finance launched a public consultation on additional measures to combat dividend stripping. The consultation outlines four potential measures, including two generic anti abuse rules – i.e., the "net return approach" and the "German Austrian style holding requirement" – as well as two targeted measures aimed at pension funds and group situations. The pension fund rule is designed to prevent pension funds from being used as intermediaries to obtain exemptions, credits, or refunds of Dutch dividend withholding tax where the underlying economic interest in the shares remains with another party. Under this proposal, a pension fund would lose its entitlement to relief where the dividend is connected to a business activity that falls outside its regular pension investment activities. Indications of such a business activity include price risk hedging, financing the share position, and briefly holding the shares around the registration date.

April 18, 2026: Netherlands Issues 2025 Developing Countries List for Unilateral Tax Relief[27]

The Dutch Ministry of Finance has published the list of developing countries for 2025, whose taxes qualify for a unilateral tax credit for Dutch residents receiving dividends, interest, or royalties. This credit, granted under the Decree on the Avoidance of Double Taxation 2001, applies where no tax treaty is in place (or where a treaty refers back to domestic law), and allows a credit up to the Dutch tax attributable to the income, provided the income is subject to tax in the source country.

April 23, 2026: Update on Tax Treaty Negotiations[28]

The Dutch Ministry of Finance published its annual letter outlining the status of tax treaty negotiations. The letter, among other things, covers the new tax treaties with Belgium, Spain, and Brazil. The new tax treaty between the Netherlands and Belgium was signed on June 21, 2023. Both countries have since been working on a joint explanatory memorandum. The ministry aims to submit the new tax treaty to Parliament in 2026. Approval for the signing of the new tax treaty between the Netherlands and Spain was granted by the Dutch Council of Ministers in 2023. Following this approval, further discussions were held with Spain on several technical points, on which agreement was reached by the end of 2025. The aim is to sign the new tax treaty in the first half of 2026, and subsequently submit it to Parliament in 2026. The new tax treaty with Brazil is still being negotiated. The ministry notes that these negotiations are at an advanced stage, with the aim of reaching an agreement in 2026.

Spain

April 29, 2026: European Commission Issues Reasoned Opinion on Spain’s Real Estate Tax for Non‑Residents[29]

The European Commission has issued a reasoned opinion to Spain, concluding that its domestic tax rules applicable to non‑resident taxpayers’ habitual residences are incompatible with EU law. While non-resident taxpayers are subject to a deemed income tax on real estate, residents are exempt when the property constitutes their habitual residence. The Commission considers this differential treatment contrary to the free movement of capital under Article 63 of the Treaty on the Functioning of the EU. Spain has been granted two months to respond, after which the Commission may escalate the matter to the Court of Justice of the European Union.

Switzerland

April 07, 2026: Switzerland Confirms Application of OECD Pillar Two Side‑by‑Side Safe Harbour Rules[30]

The Swiss Federal Tax Administration clarified that the OECD Pillar Two Side‑by‑Side Safe Harbor Package, adopted by the OECD/G20 Inclusive Framework on January 05, 2026, is directly applicable in Switzerland under Article 2(3) of the Minimum Taxation Ordinance. Accordingly, Switzerland will apply all five OECD‑adopted safe harbors, including the extended Transitional CbCR Safe Harbor (for FYs beginning by December 31, 2027, and ending no later than June 30, 2029), the Substance‑based Tax Incentive, Side‑by‑Side, and UPE Safe Harbors (for FYs beginning on or after January 01, 2026), and the Simplified ETR Safe Harbor (for FYs beginning on or after December 31, 2025), subject to applicable conditions.

United Kingdom

April 02, 2026: Court Ruling: Revenue and Customs Commissioners v Tailored UK Services Ltd [2026] UKFTT 518 (TC)[31]

The First-tier Tribunal (Tax Chamber) allowed HMRC's application for a penalty to be imposed on Tailored UK Services Limited (in liquidation) for failure to notify tax avoidance arrangements under the Disclosure of Tax Avoidance Schemes (DOTAS) provisions. The company was a promoter of notifiable arrangements known as the "enhanced umbrella scheme," which should have been notified to HMRC by August 25, 2017, but were not disclosed until June 14, 2022, by the liquidators. The Tribunal found that the arrangements were notifiable arrangements within section 306(1) Finance Act 2004 (FA 2004), as previously determined in the DOTAS decision of May 06, 2022. The company failed to comply with its statutory obligation under section 308 FA 2004 to notify HMRC within the prescribed five-day period after first becoming aware of any transaction forming part of the arrangements. The Tribunal rejected any reasonable excuse defense, finding that neither the company’s directors before liquidation nor the liquidators after appointment acted as responsible traders, conscious of and intending to comply with DOTAS obligations. The penalty application was made within the six-year limitation period under section 103(4) of the Taxes Management Act 1970.

April 09, 2026: HMRC Opens Consultation on Carbon Border Adjustment Mechanism (CBAM) (Emissions and Verification) Draft Regulations[32]

HMRC published a technical consultation on draft secondary legislation for the UK Carbon Border Adjustment Mechanism (CBAM), focusing on emissions calculation and verification requirements. The draft regulations, intended to take effect on January 01, 2027, alongside the introduction of CBAM, set out provisions relating to tax administration, including the monitoring of embodied emissions and verification of emissions data. HMRC is seeking feedback to ensure the legislation delivers the policy intent and adequately addresses administrative matters. Draft notices with force of law has also been issued to explain how the legislation and guidance will operate together, though they are not formally part of the consultation. The consultation is relevant for UK importers, overseas producers, and emissions verifiers, and closes on May 21, 2026. It is separate from the earlier consultation on other CBAM secondary legislation covering administration, CBAM rate, and carbon price relief, which closed on March 24, 2026.

April 20, 2026: SI 2026/427: Charities Acts 1992 and 2011 (Substitution of Sums) Order 2026[33]

This Order increases specified financial sums and thresholds by amending the Charities Act 1992 (CA 1992) and the Charities Act 2011 (CA 2011), and by amending the Charities Act 2011 (Group Accounts) Regulations 2015, SI 2015/322. It substitutes higher amounts used in parts of the regulatory regime, including thresholds linked to professional fund-raisers and collectors, donor-cancellation rights, the Charity Commission’s jurisdiction threshold on application, and income thresholds relevant to receipts and payments accounts, audit and independent examination, and the preparation and audit of group accounts. It also makes transitional provision so that certain pre-commencement matters continue to be dealt with under the previous thresholds. It comes into force on September 30, 2026.

April 24, 2026: HMRC Guidance Updates: Corporate Interest Restriction Returns[34]

HMRC has updated its guidance on submitting a Corporate Interest Restriction (CIR) return to reflect changes applicable to periods of account ending on or after March 31, 2026. The guidance clarifies that, for such periods, a reporting company appointed by a group is required to submit a return only if the group wants to allocate disallowed amounts to specific group companies, carry forward unused interest allowance, claim a reactivation of disallowed amounts, or make an election, such as for the group ratio method.

April 29, 2026: HMRC Updates Exchange of Information Agreements Notice[35]

HMRC has issued a Notice under the International Tax Compliance Regulations 2015 (SI 2015/878, reg 1(3)(b)) to bring the UK’s arrangements for the exchange of tax information up to date, confirming that agreements entered into with other territories as at April 15, 2026, are within scope. The Notice, which has force of law, links to the HMRC International Exchange of Information Manual for the lists of reportable jurisdictions (IEIM402340) and participating jurisdictions (IEIM400090). While it is not immediately clear whether the revocation of reg 1(3)(b) by SI 2025/740 affects the legal status of the Notice, it states that, for reporting obligations from calendar year 2026 onward, future notices will be issued under reg 1(7)(c) and (d) of the 2015 Regulations, which reference the relevant jurisdiction lists.

China

April 01, 2026: Data Governance Mandates Integrated Into Authorized Economic Operator (AEO) Protocols[36]

In April 2026, the General Administration of Customs (GACC) issued Announcement No. 24, revising the accreditation standards for Authorized Economic Operators (AEOs). The update integrates stricter digital trade document security and cross-border data transfer compliance into the AEO scoring matrix, aligning with China's Data Security Law. Supply chain executives are experiencing significant friction when coordinating customs clearance schedules. Internal disputes frequently arise regarding whether routine logistics data shared with overseas headquarters violates newly instituted localization thresholds, occasionally disrupting fast-track processing at major ports.

April 13, 2026: New Inter-Agency Framework Targeting Extraterritorial Legal Overreach[37]

On April 13, 2026, the State Council issued Decree No. 835 with immediate effect, marking the enforcement of an updated administrative decree designed to buffer domestic market participants against foreign mandates. The mechanism penalizes multinational organizations that enforce discriminatory overseas compliance protocols within Chinese borders, introducing operational bottlenecks for non-compliant entities while establishing a centralized cross-agency mechanism coordinating the Ministries of Justice, Customs, and Commerce. It also introduces a Malicious Entity List and expands China’s retaliatory toolkit, allowing for asset freezes, transaction bans, and data-transfer restrictions. As a result, multinational corporations operate in an increasingly polarized compliance environment, where adapting to unilateral Western sanctions may trigger local asset blockages or litigation risks. This shift is driving companies away from standardized global compliance toward more complex, region-specific mitigation strategies.

April 22, 2026: Consumption Tax – Intensified, Granular Audits on Indirect Transfer Pricing for Luxury and Beverage Sectors[38]

In April 2026, China introduced enhanced tax-reporting requirements for the beer and Baijiu sectors, mandating SKU-level disclosure of ex-factory and taxable prices, with clear segregation between related and third-party transactions to identify potential transfer pricing practices. A new “price comparison rule” for beer was also implemented to prevent tax bracket manipulation. While currently limited to these sectors, the measures signal a broader shift toward data-driven, cross-entity pricing scrutiny through digital tax systems. This development raises compliance concerns for the wider market, particularly for multinationals operating complex related-party distribution models. Companies should closely monitor the potential extension of such “price alignment” mechanisms to other high-value or FMCG sectors in China.

India

April 01, 2026: CBDT Amends Income Tax Rules To Protect Pre-2017 Investment Income From GAAR[39]

The Central Board of Direct Taxes (CBDT) of India has issued Notification No. 55/2026 and 54/2026, amending Rule 128 of the Income-tax Rules, 2026, and Rule 10U of the Income-tax Rules, 1962, to clarify that the General Anti-Avoidance Rules (GAAR) do not apply to income arising from investments made before April 01, 2017, thereby removing uncertainty in the grandfathering provisions. The amendment, which takes effect on April 01, 2026, is intended to address the ambiguity that arose following the Supreme Court’s judgment in Tiger Global International II Holdings.

Japan

April 01, 2026: Japan Adopts 2026 Tax Reform Package Implementing Side-by-Side Safe Harbor and Related Pillar Two Measures[40]

Japan has enacted its 2026 tax reform package, implementing the OECD/G20 side-by-side safe harbor and related Pillar Two safe harbors. Approved by the Diet on March 31, 2026, and effective from April 01, 2026, the package deems the Top-up Tax to be zero under the income inclusion rule and the undertaxed profits rule for qualifying side-by-side regimes, including the United States. It also introduces the ultimate parent entity safe harbor, the substance-based tax incentive safe harbor, and extends the transitional country-by-country reporting safe harbor by one year, so that it applies to fiscal years beginning between April 01, 2024, and December 31, 2027. Separately, the OECD’s administrative guidance on Article 9.1 of the GloBE Model Rules has been incorporated into domestic law, applying to fiscal years beginning on or after April 01, 2026.

Singapore

April 07, 2026: Singapore Unveils Supplementary Support Package To Address Energy Price Surge[41]

Singapore announced an additional support package to help businesses and households cope with higher energy costs linked to the Middle East conflict, adding around SGD 1 billion in tax and non-tax measures on top of Budget 2026.

Please refer to the A&M Tax[42] Alert for detailed analysis.

April 15, 2026: Singapore Signs GloBE Information Return Multilateral Competent Authority Agreement[43]

On April 14, 2026, Singapore signed the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Global Anti-Base Erosion (GloBE) Information. Under the Pillar Two GloBE rules, each MNE group entity is generally required to file a GloBE Information Return (GIR) in its local jurisdiction, but this obligation can be discharged through central filing, where the GIR is filed in a jurisdiction with an active exchange relationship. By signing the Multilateral Competent Authority Agreement on the Exchange of GloBE Information, Singapore enables central filing of the GIR, thereby reducing compliance burdens for Singapore‑headquartered MNE groups by limiting the number of jurisdictions requiring separate filings, while ensuring that GIR information is exchanged only with partners that have robust confidentiality and data‑protection safeguards.

Hong Kong

April 01, 2026: 2025/26 Profits Tax Returns Issued[44]

The Inland Revenue Department (IRD) issued profits tax returns for the year of assessment 2025-26. The first phase of mandatory electronic filing of profits-tax returns has come into effect. Hong Kong entities within in-scope MNE groups under the global minimum tax (Pillar Two) regime must file profits-tax returns electronically from the 2025-26 year of assessment onward via the IRD online portal.

April 01, 2026: The IRD Publishes First Advance Ruling on Ship Leasing Tax Concession[45]

The IRD published its first advance ruling on the application of Hong Kong’s ship leasing tax concession regime, confirming that a Hong Kong ship leasing company satisfied the statutory conditions to be treated as a qualifying ship lessor and to apply the 0% concessionary profits tax rate to qualifying income. The ruling sheds light on the IRD’s approach in assessing eligibility for the concession, particularly regarding business substance in Hong Kong, qualified personnel, and the conduct of ship-leasing activities.

April 21, 2026: Hong Kong Signs GloBE Information Return Multilateral Competent Authority Agreement[46]

Hong Kong has been included in the OECD’s list of signatories to the MCAA, enabling centralized filing of GIRs for MNE groups and the exchange of Pillar Two reporting information between tax authorities.

Vietnam

April 29, 2026: Vietnam Updates Tax Framework With Decree No. 141/2026/ND-CP[47]

New Decree No. 141/2026/ND-CP, issued on April 29, 2026, amends provisions under Decree 68/2026 on tax policy for household businesses (HBs) and individual businesspersons (IBs), as well as Decree 320/2025 on Corporate Income Tax (CIT), with effect from January 01, 2026. A key change is an increase in the revenue threshold from VND 500 million to VND 1 billion, effectively doubling the VAT and PIT exemption limit for HBs and IBs. Under the revised rules, taxpayers with annual revenue not exceeding VND 1 billion are generally exempt from VAT and PIT. Conversely, HBs and IBs exceeding this threshold must adopt e-Invoicing systems connected to tax authorities. Additionally, certain enterprises and organizations with annual revenue not exceeding VND 1 billion may qualify for CIT exemption, subject to prescribed conditions.

Qatar

April 22, 2026: Qatar Grants Extension for 2025 Tax Return Filing Deadline[48]

Qatar’s General Tax Authority has extended the 2025 tax return filing deadline to June 30, 2026, for most taxpayers to support compliance. Petroleum and petrochemical companies remain subject to the original April 30, 2026, deadline.

April 01, 2026: Qatar Introduces “Trusted Entity” Regime for At-Source Treaty Withholding Tax Relief[49]

Qatar’s General Tax Authority (GTA) has introduced a “Trusted Entity” regime that allows eligible Qatar-based taxpayers to apply tax treaty withholding tax (WHT) relief at source, instead of following the earlier refund-based process. Under the regime, approved entities can directly apply reduced treaty rates or exemptions to payments made to non-residents, subject to satisfying eligibility conditions, maintaining adequate governance controls, and submitting supporting documentation. Trusted entity status is generally valid for three years and permits entities to review foreign recipient applications, issue approval forms, and grant treaty relief when recipients provide documents such as tax residency certificates, beneficial ownership confirmations, and evidence of economic substance. Approved entities are required to complete due diligence within 60 days, report transactions through the Dhareeba portal by the 16th of the following month, and retain relevant documentation. Relief approvals remain valid until the earlier of the trusted entity status expiry or 12 months from the issuance of the tax residency certificate, with penalties applicable for misuse. The regime became effective from April 12, 2026, and is intended to simplify compliance procedures and improve cash flow for taxpayers.

Australia

April 10, 2026: Australia Publishes Draft Legislation Expanding Scope of Foreign-Resident Capital Gains Tax[50]

The Australian government has released draft legislation proposing to strengthen the foreign-resident capital gains tax regime by broadening the scope of taxable Australian property and clarifying the asset categories covered, including assets with a close economic connection to land, irrespective of their treatment under state and territory property law. The draft also proposes a 365-day principal asset test for indirect interests, new pre-transaction notification requirements, revised withholding rules for non-compliance, and a limited, transitional 50% capital gains tax concession for eligible renewable energy assets disposals completed by June 30, 2030. Certain amendments are intended to apply retrospectively from 2006; however, the Australian Taxation Office (ATO), in a note dated April 21, 2026, has indicated that the retrospective changes are unlikely to affect most taxpayers and are mainly intended to clarify the law for those under review.

April 24, 2026: ATO Finalizes Revised Transfer Pricing Compliance Guideline for Inbound Distribution Arrangements[51]

The ATO has released revised guidance under Practical Compliance Guideline (PCG) 2019/1, refining its approach to transfer pricing risk assessment for inbound distribution arrangements, which typically involve Australian entities distributing goods, digital products, or services sourced from related foreign parties. The updated guidance introduces revised industry profit benchmarks based on more current financial data and provides greater clarity on scope, particularly distinguishing entities engaged in more complex functions or those engaged in developing marketing intangibles in Australia. In addition, a new “white zone” category has been introduced for taxpayers with advance pricing agreements or recent high-assurance ratings, indicating a lower likelihood of compliance review.

New Zealand

April 01, 2026: Inland Revenue Revises Transfer Pricing Documentation Standards and Penalty Framework[52]

Inland Revenue (IR) updated its transfer pricing documentation guidance on March 31, 2026, addressing penalty exposure, recurring taxpayer errors, and the characteristics of adequate documentation. IR emphasizes that inadequate documentation is likely to trigger penalties when a transfer pricing adjustment is proposed, including a possible 40% shortfall penalty for gross carelessness where material related-party transaction issues are overlooked. The guidance also highlights common documentation failures, such as mischaracterizing entities as subsidiaries or branches, omitting transaction parties, misreading contracts, conducting weak agency analysis, performing superficial comparables work, and over-relying on parent-prepared global documentation without reflecting local facts.

• On April 02, 2026, President Trump issued a proclamation imposing a 100% tariff on imported patented pharmaceutical products and related ingredients, citing national security concerns and the objective of encouraging local pharmaceutical manufacturing. Preferential rates apply to select trading partners, including 15% for imports from the European Union, Japan, South Korea, Switzerland, and Liechtenstein, and 10% for United Kingdom imports, reflecting prior bilateral trade arrangements with these jurisdictions. Companies submitting approved domestic production relocation plans may qualify for a reduced 20% rate, while those entering into pricing agreements with the Department of Health and Human Services may access a 0% rate through January 20, 2029. Generic drugs, biosimilars, and their active ingredients are presently excluded, with potential exemptions also available for certain orphan drugs, animal health products, and specialty pharmaceuticals. The tariffs take effect on July 31, 2026, for larger companies and on September 29, 2026, for smaller ones. The measure formalizes pharmaceutical tariff policy previewed by the administration in September 2025, and builds on subsequent bilateral trade understandings with key partners.[53]
• On April 02, 2026, the United States announced that it will maintain its 50% Section 232 tariffs on a broad range of imported steel, aluminum, and copper, while introducing revised rates for select downstream and equipment categories under a new presidential proclamation. Effective April 06, 2026, duties will be calculated on the total import value rather than just the metal portion. While many core metal products remain subject to the 50% rate, certain derivatives will see reduced tariffs of 25% or 15%, with specific industrial equipment receiving temporary relief until December 31, 2027. Additional adjustments include lower tariffs for domestically sourced metal content, and exemptions for products with minimal metal composition. The updated framework also streamlines how new products are added to the tariff list and mandates a review within 90 days.[54]
• On April 20, 2026, US Customs and Border Protection (CBP) launched Phase 1 of its Consolidated Administration and Processing of Entries (CAPE) functionality, allowing importers of record and authorized customs brokers to submit claims for refunds of certain additional tariffs imposed under the International Emergency Economic Powers Act (IEEPA). Phase 1 applies to certain unliquidated entries and to entries within the voluntary-reliquidation period, with additional circumstances to be addressed in later phases. CBP reported that, as of May 11, the anticipated duty refund and interest amount for more than 8.3 million entries was approximately $35.5 billion, representing the anticipated principal to be refunded and associated interest due.[55]
• On April 27, 2026, India and New Zealand signed a Free Trade Agreement in New Delhi, formalizing an already initialed deal aimed at deepening bilateral economic engagement and strategic cooperation. The agreement provides for tariff elimination and reduction to significantly expand bilateral trade, improved market access for services, and strengthened institutional frameworks. It is also designed to support investment flows, employment generation, and export growth, with particular focus on creating opportunities for entrepreneurs, MSMEs, and students across multiple sectors.[56]