Setting the Context: What Is the Consultation About

Over the past decade, taxation of the digital economy has shifted from a question of policy design to one of implementation and enforcement. Digital platforms now play a central role in facilitating economic activity, connecting service providers, sellers, and consumers across borders with increasing scale and sophistication. In parallel, this transformation has created visibility gaps for tax administrations, particularly regarding income earned by sellers operating through such platforms.

The OECD’s introduction of the Model Reporting Rules for Digital Platforms (MRDP) in 2020[1], followed by their expansion in 2021[2], represented a coordinated attempt to address these gaps. By placing reporting obligations on platform operators rather than individual sellers, the framework leverage existing data flows within the digital ecosystem to improve tax transparency. Since then, a growing number of jurisdictions have implemented or aligned domestic reporting regimes with the OECD model, reflecting broader adoption of platform-based reporting standards.

Against this backdrop, on June 15, 2026[3], the OECD initiated a public consultation to seek feedback on targeted amendments to the MRDP framework, in particular to improve reporting outcomes for intermediary sellers. The consultation focuses on issues identified through implementation experience and considers amendments to specific aspects of the Model Rules, the Optional Module, and related commentaries. The proposals are intended to address operational and interpretative issues that have emerged since the framework was introduced.

Understanding the Framework: What Are the Model Reporting Rules?

The MRDP framework is built on a simple premise: digital platforms are best positioned to collect and report information on the economic activity they facilitate. Accordingly, platform operators must undertake due diligence procedures to identify reportable sellers, collect specified information, including identity details, jurisdiction of residence, and consideration received from relevant activities and report this information to the tax authority in their jurisdiction. Through an established multilateral exchange mechanism, the reported information is shared with other relevant jurisdictions, enabling tax authorities to access structured, standardized data on both domestic and cross-border platform-based transactions.

Conceptually, the MRDP reflects the broader evolution of international tax transparency, drawing on principles established in earlier information reporting regimes while adapting them to the realities of the digital economy. Its distinguishing feature is the recognition that digital platforms occupy a unique position as intermediaries, with visibility into transactions that traditional third-party reporting mechanisms often could not capture. By embedding reporting obligations within the operational framework of platform operators, the MRDP aims to improve tax compliance through a globally consistent and scalable reporting standard.

Notwithstanding its conceptual clarity, the diversity of platform business models, ranging from pure intermediaries to hybrid operators, has made uniform application challenging.

What Is Being Proposed: Targeted Changes With a Practical Focus

The OECD’s proposed amendments are targeted and focus on specific issues identified through implementation experience. They address areas where practical application of the rules has given rise to operational and interpretive challenges.

A prominent area under review is the treatment of low-value goods transactions. Under the current rules, a seller is excluded from reporting when fewer than 30 Relevant Activities have been facilitated and total consideration does not exceed EUR 2,000 during the reporting period. Business representatives have raised concerns that the combined application of these thresholds may impose reporting obligations on private individuals undertaking occasional low-value sales, such as second-hand goods, even though such activities are unlikely to give rise to a tax liability. The proposed amendments would simplify the exclusion by removing the activity threshold and increasing the monetary threshold to EUR 3,000, thereby simplifying the exclusion criteria and potentially reducing reporting obligations for certain low-value transactions.

Another key focus is clarification of core definitions within the framework. Terms such as ‘Platform’ and ‘Platform Operator’ are fundamental to determining the scope of reporting obligations, yet their interpretation has not always been consistent across jurisdictions and business models. The proposed amendments would clarify the characteristics of a platform, the circumstances in which an entity qualifies as a platform operator, and the distinction between platform operators and entities performing purely technical functions, such as payment processors. By refining these definitions, the OECD aims to reduce interpretive uncertainty and promote more consistent application of the rules.

The consultation also addresses the potential duplication where a seller is itself a Reporting Platform Operator. In such cases, requiring full transactional reporting at multiple levels of the platform ecosystem may duplicate reporting and increase compliance obligations. The proposed amendments therefore introduce a tailored reporting approach under which only identifying information and tax residency would be reported, supported by dedicated due diligence procedures to identify such sellers. The objective is to reduce duplication while preserving the integrity of the information available to tax authorities.

The consultation also proposes targeted relief for certain intra-group arrangements through introduction of a ‘Related Entity’ concept. Under the proposed approach, Related Entities of a Platform Operator would be treated as Excluded Sellers, limiting reporting obligations when transactions occur within closely connected group structures. Where a Platform Operator facilitates activities exclusively involving such Related Entities, it may also qualify as an Excluded Platform Operator. This amendment recognizes that certain internal group arrangements may not present the same reporting considerations as transactions involving external sellers, while helping streamline compliance processes for affected platform groups.

Further the consultation considers changes to improve reporting outcomes where sellers act as intermediaries rather than ultimate providers of goods or services. As digital platform ecosystems have evolved, professional intermediaries such as property managers, travel agencies, and fleet operators are increasingly transacting on behalf of underlying property owners or individual service providers. This can result in reporting being directed to the intermediary, while the persons who ultimately receive the economic benefit remain outside the reporting framework. To address this, the OECD is exploring amendments that would expand the scope of ‘Platform Operator’ to capture certain intermediary entities that effectively provide sellers with access to a platform, thereby improving the accuracy and completeness of information reported to tax authorities.

Why It Matters: Implications for Businesses

Although the consultation does not introduce immediate changes to the Model Rules, it sets out proposed amendments for stakeholder feedback. The proposals address implementation challenges that have emerged since the framework was introduced and focus on areas such as reporting thresholds, key definitions, duplicative reporting, and intermediary arrangements.

For platform operators, the consultation is an opportunity to assess whether existing compliance processes remain fit for purpose. Proposed changes to reporting thresholds, exclusions, and key definitions could require updates to due diligence procedures, data collection processes, and reporting systems if ultimately adopted. At the same time, measures aimed at simplifying reporting in low-risk scenarios and reducing unnecessary duplication could ease administrative burdens while preserving the quality of information available to tax authorities.

More broadly, the consultation reflects the OECD’s ongoing review of the Model Rules in light of evolving business models and practical implementation experience. While the proposed amendments focus on specific operational and interpretive issues identified through implementation, they address a number of areas that have emerged from application of the framework across multiple jurisdictions. Businesses may wish to monitor the consultation process and assess how any final amendments could affect their reporting and compliance obligations.

The Road Ahead: Consultation Timeline and Engagement

The OECD has invited stakeholders to submit comments on the proposed amendments by August 14, 2026. The consultation presents an important opportunity for platform operators, businesses, advisors, and industry bodies to share practical implementation experience and contribute to the future development of the MRDP framework.

More broadly, the consultation reflects the OECD's commitment to refining the Model Rules in response to evolving business models and practical implementation experience. While the proposed amendments are targeted rather than transformative, they signal a continued effort to balance tax transparency with proportionate and effective compliance obligations. Businesses should therefore view this consultation not only as an opportunity to influence the final rules but also as an early indication of the framework's future direction.

USA

June 04, 2026: Court Holds Staking Rewards Taxable When Credited To Account[4]

The US Tax Court in Paschall v. Commissioner held that cryptocurrency staking rewards are taxable as ordinary income when credited to the taxpayer’s account, even if the tokens are not sold. The court noted existing IRS guidance treating cryptocurrency as property but emphasized that its decision was based on section 61 and related case law. The court concluded that the taxpayers realized income when the rewards were credited to their account and under their control, rejecting arguments that taxation should be deferred until sale or that the rewards should be treated like stock dividends. The court also held that temporary transfer restrictions did not negate ownership or control over the rewards.

June 06, 2026: Court Vacates IRS ‘Beginning of Construction’ Notice for Wind and Solar Credits[5]

The US District Court for the District of Columbia, in Oregon Environmental Council v. Internal Revenue Service, vacated IRS Notice 2025-42, which had restricted how taxpayers may establish that construction began for certain wind and solar energy projects eligible for the section 45Y clean electricity production tax credit and the section 48E clean electricity investment tax credit. The One Big Beautiful Bill Act (OBBBA) accelerated the phaseout of those credits for applicable wind and solar facilities if construction begins after July 04, 2026, and the facilities are placed in service after December 31, 2027. The notice eliminated the Five Percent Safe Harbor Test, leaving the Physical Work Test as the primary method for applicable wind and solar projects to satisfy the beginning-of-construction requirement. The court held that the IRS failed to adequately explain its departure from prior guidance and did not sufficiently justify treating wind and large-scale solar projects differently from other clean energy projects. As a result, the court vacated the notice and remanded the matter to the IRS for further consideration.

June 16, 2026: Court Allows Partial Research Credits[6]

The US Tax Court in Smith v. Commissioner held that four of six representative projects were eligible for reduced research credits. The IRS argued that the activities were excluded as funded research under section 41(d)(4)(H) and that the partners’ 2008 compensation was unreasonable under section 174(e). Although the statute does not define ‘funded research,’ the regulations generally treat research as funded if payment is not contingent on research success or if the taxpayer does not retain substantial rights in the research. Because the partnership retained substantial rights in four projects, the court held that it may claim reduced research credits for those projects to the extent research expenses exceeded payments received. The court also held that the partners’ 2008 compensation was reasonable under section 174(e), applying the independent investor test consistent with Seventh Circuit precedent.

June 01, 2026: Minnesota Enacts Internal Revenue Code Conformity Changes, Extends Pass-Through Entity Tax, and Launches New Fraud Tax[7]

Minnesota enacted H.F. 2438, signed by Governor Tim Walz on May 27, 2026, updating the state's static conformity date to the Internal Revenue Code (IRC) to May 01, 2026. The legislation adopts most provisions of the OBBBA while selectively decoupling from several federal tax measures, including certain charitable deductions, education assistance, the business meal deduction, and foreign income provisions. The law also restores Minnesota's Pass-Through Entity Tax (PTET), retroactive to January 01, 2026, and extends it through tax year 2027, allowing eligible entities to pay state tax at the entity level. In addition, H.F. 2438 introduces a new fraud tax equal to 100% of the public program fraud amount for convictions occurring after December 31, 2025, reinforcing the state's efforts to address fraud involving public programs.

June 01, 2026: North Carolina Voters To Decide on Lower Maximum State Income Tax Rate[8]

North Carolina enacted Session Law 2026-4, placing a constitutional amendment before voters that would reduce the maximum allowable state income tax rate from 7% to 3.5% for both individual and corporate income taxes. The proposal will be considered at the general election on November 03, 2026, and, if approved, would take effect for taxable years beginning on or after January 01, 2027. While the amendment would not immediately lower current tax rates already scheduled to decline below 3.5% under existing law, it would limit the state's ability to increase personal or corporate income tax rates above that threshold in the future.

June 13, 2026: Arizona Aligns Selectively With Federal OBBBA, Suspends New Data Center Tax Incentives[9]

Arizona enacted House Bill 4168, updating its tax code to selectively conform to provisions of the OBBBA. For tax year 2025, the state adopted several federal tax benefits, including higher standard deductions, deductions of up to USD 25,000 for qualified tips, USD 12,500 (USD 25,000 for joint filers) for qualified overtime compensation, and USD 6,000 for eligible taxpayers aged 65 and older. Arizona also allows a deduction of up to USD 10,000 for qualified passenger vehicle loan interest in 2025. However, beginning in 2026, the state will exclude certain OBBBA provisions, including the increased State and Local Tax (SALT) deduction cap of USD 40,000, instead retaining its USD 10,000 limit. The legislation also imposes a three-year moratorium on new computer data center tax incentives, suspending new applications for tax exemptions from July 01, 2026, through June 30, 2029. Additional measures include increasing the dependent tax credit from USD 100 to USD 125, expanding property tax relief for disabled veterans and surviving spouses, and capping the statewide Corporate Low-Income Student Tuition Tax Credit at USD 110 million annually beginning in 2027.

Canada

June 18, 2026: Canada Enacts Tax Measures Under Spring Economic Update 2026[10]

Canada’s Bill C-30, the Spring Economic Update 2026 Implementation Act, received Royal Assent on June 18, 2026, implementing numerous tax measures first proposed in Budget 2025 and in draft legislation released across 2024, 2025, and early 2026. The legislation provides immediate expensing for eligible manufacturing buildings acquired after November 03, 2025, and relief by preventing corporations formed on a vertical amalgamation from being deemed public corporation merely because a predecessor corporation was public. The legislation also tightens certain anti-avoidance rules targeting debt forgiveness manipulation, trust-to-trust transfers designed to reset the 21-year deemed disposition rule, suspended dividend strategies in corporate groups with staggered year-ends, and indirect transfers to avoid section 160 liabilities. The legislation provides for new and expanded clean economy investment tax credits for carbon capture, utilization, and storage (CCUS), clean hydrogen, clean electricity, and clean technology projects to promote capital investment in Canadian clean technologies. It further aligns foreign affiliate rules with the global minimum tax by allowing credits for domestic minimum top-up taxes (retroactive to December 31, 2023) and implements Canada's Pillar Two undertaxed profits rule for fiscal years commencing on or after December 31, 2025. In addition, the legislation expands the Canada Revenue Agency's (CRA) audit powers through new non-compliance notice provisions, enhancing the tax authority's enforcement capabilities.

European Union

June 30, 2026: European Commission Publishes EU Tax Omnibus Directive Proposal and Court Developments[11]

The European Commission released a series of significant tax proposals and judicial developments aimed at simplifying and modernizing the EU tax framework. Key highlights include the proposed Tax Omnibus Directive, which seeks to streamline major directives, such as ATAD, Interest and Royalties, and Parent-Subsidiary, alongside the DAC recast proposal to consolidate and simplify administrative cooperation rules. In parallel, recent rulings from the CJEU and EGC clarify important positions on RETT applicability, the VAT treatment of loan servicing, and interest limitation rules for securitization vehicles. Collectively, these developments signal a shift toward simplification, broader access to tax reliefs, and alignment with Pillar Two principles, while also raising practical considerations for taxpayers across the EU.

Please refer to A&M Tax Alert[12] for detailed analysis.

Ireland

June 26, 2026: Irish Revenue Extends Dividend Withholding Tax Exemption To Qualifying Partnerships[13]

Irish Revenue revised its dividend withholding tax guidance to allow qualifying Irish partnerships and certain equivalent foreign partnerships to receive dividend payments without dividend withholding tax being deducted at source. The updated approach recognizes the tax-transparent nature of partnerships and permits the exemption to be assessed by reference to the underlying partners, provided they are themselves eligible for relief and specified conditions are satisfied. This change is expected to reduce administrative burdens by eliminating the need for withholding and subsequent refund claims in qualifying cases.

France

June 10, 2026 – France Updated Its Administrative Guidance on Article 209 B (French CFC rules)[14]

The French tax authorities updated their administrative guidance (BOI-IS-BASE-60-10-20-20) on the French controlled foreign company (CFC) regime (Article 209 B of the French Tax Code). The revised guidance confirms that foreign participation exemption regimes applicable to dividend income and capital gains derived from qualifying shareholdings do not, by themselves, constitute a preferential tax regime for purposes of Articles 209 B and 238 A of the French Tax Code, even where no deemed expense add-back mechanism applies. By confirming and extending its administrative position in light of recent case law, the French tax authorities have provided additional certainty for multinational groups holding foreign subsidiaries.

Germany

June 18, 2026: Ireland Revises Dividend Withholding Tax Rules, Allowing Exemptions for Eligible Partnership Structures[15]

Germany’s Federal Ministry of Finance released revised administrative guidance on the determination and creation of Permanent Establishments (PEs) for both domestic and cross-border tax purposes. The updated framework explains the key conditions that must be satisfied for a PE to exist under Section 12 of the German Fiscal Code and provides greater clarity on how these rules interact with tax treaty provisions based on Article 5 of the OECD Model Tax Convention. The guidance incorporates recent court decisions from Germany’s Federal Fiscal Court and reflects the latest OECD commentary, aiming to create a more consistent approach for taxpayers and tax authorities when assessing taxable business presence and related taxing rights in international operations.

Netherlands

June 25, 2026: Dutch Supreme Court Denies Box 3 Relief for Non-Objecting Taxpayers[16]

The Dutch Supreme Court held that taxpayers who did not lodge a timely objection against their Box 3 income tax assessments for the 2017–2020 tax years are not entitled to a reduction based on the Court's December 2021 ‘Christmas Decision’ through an ex officio reassessment. The Court confirmed that the statutory six-week objection period remains applicable, and that a subsequent judicial ruling does not justify reopening tax assessments that have already become final. It further held that the ‘new case law’ exception under the Income Tax Regulation 2001 precludes relief where the request is based solely on a later court judgment. The Court also rejected arguments that this outcome violated the principles of equal treatment, proportionality, or the right to an effective remedy under the European Convention on Human Rights, confirming that non-objecting taxpayers cannot benefit from the Christmas Decision.

June 25, 2026: Netherlands Introduces Transitional Relief for Fiscal Investment Institutions[17]

The Netherlands published an updated decree on Fiscal Investment Institutions (FBIs) in the Official Gazette on June 25, 2026, to address transitional issues arising from the entity classification reforms introduced on January 01, 2025. Under those reforms, certain interests held by FBIs that were previously treated as non-transparent are now regarded as tax transparent, resulting in the underlying assets and liabilities being attributed directly to the FBI. This change may affect an FBI's compliance with its profit distribution obligation and financing limit. To ease the transition, the decree allows eligible FBIs to continue treating such interests as non-transparent solely for the purposes of these two requirements for up to seven financial years, or until the relevant interest is disposed of, whichever occurs first. The relief is available upon a written election submitted to the competent tax inspector within the prescribed timeframe. The updated decree took effect on June 26, 2026, and replaces the previous decree issued in 2024.

June 18, 2026: Dutch Tax Authority Explains Treatment of Interest Rate Reductions on Intra-Group Loans[18]

The Netherlands Tax Administration issued guidance on how reductions in interest rates on loans between related entities should be treated for tax purposes. The clarification stems from a case involving a Dutch taxpayer that lowered the interest rate on a loan granted to a wholly owned foreign subsidiary from 5% to 3%, in line with a deemed arm’s-length benchmark. The authority confirmed that such a reduction constitutes a downward profit adjustment under transfer pricing rules. However, because Dutch tax legislation seeks to prevent double non-taxation arising from transfer pricing mismatches, the adjustment may be restricted when there is no corresponding taxable upward adjustment recognized by the related borrower. The guidance further confirms that Article 8bb of the Dutch Corporate Income Tax Act applies to these situations and extends to adjustments resulting from application of the arm’s-length principle to non-business-related loans, reinforcing the conditions under which interest deductions can be limited.

June 30, 2026: Dutch Ministry of Finance Defers Action on Anti-Fragmentation Measures Under the Earnings Stripping Rule[19]

The Dutch Ministry of Finance indicated that, for the time being, it will not introduce measures to counter the ‘fragmentation’ of real estate across multiple entities aimed at taking advantage of the EUR 1 million de minimis amount under the earnings stripping rule. The EUR 1 million de minimis applies per corporate taxpayer. Although such measures have been under consideration for several years, the Ministry has decided to postpone further action in light of expected amendments to the EU earnings stripping rule under the EU Tax Omnibus Directive. The Ministry noted that previously considered policy options either had overly broad and disproportionate effects, failed to fully address base erosion concerns, or would create significant administrative burdens.

June 30, 2026: Dutch Ministry of Finance Launches Public Consultation on Simplifying Profit Taxation[20]

The Dutch Ministry of Finance launched a public consultation as part of its ‘Simplifying Profit Taxation’ project, inviting interested parties to share practical experiences regarding complexity and administrative burdens within profit taxation. The initiative reflects broad support for simplification at both the EU and domestic level and seeks to identify rules and processes that are difficult to apply or that create disproportionate compliance costs. The consultation covers corporate income tax, business taxation within the personal income tax system, dividend and conditional withholding taxes, and related regimes. It excludes Pillar Two. The consultation will be open for submissions until August 3, 2026.

Spain

June 11, 2026: Spanish Supreme Court Confirms Direct Liability of Withholding Agents for Under-Withheld Tax[21]

In Judgment No. 737/2026, the Spanish Supreme Court established binding case law confirming that the Tax Authorities may assess unwithheld taxes directly against the withholding agent, without first regularizing the tax position of the income recipients. The Court reiterated that the obligation to withhold is an autonomous tax obligation, separate from the underlying tax liability of the recipient. Accordingly, where insufficient withholding has been applied, the Tax Authorities may claim the unpaid withholding tax, together with late-payment interest and penalties, directly from the withholding agent. The only limitation arises where the recipient has already paid the underlying tax, as otherwise a double collection would occur. However, the burden of proof rests on the withholding agent. By establishing this doctrine, the Supreme Court confirms that the Tax Authorities are not required to first verify or regularize the tax position of the income recipients before pursuing the withholding agent. This significantly increases the exposure associated with withholding tax errors and reinforces the importance of reviewing withholding tax procedures and controls, particularly for employment income and cross-border payments.

United Kingdom

June 01, 2026: UK Tribunal Limits HMRC Information Requests in Transfer Pricing Enquiry[22]

In Lifeplus Europe Ltd v HMRC, the UK First-tier Tribunal ruled in favor of the taxpayer, finding that HMRC could not compel production of a US parent company's financial statements as part of a transfer pricing enquiry. The Tribunal concluded that the requested documents were neither reasonably required to review the taxpayer’s position nor within the taxpayer's possession or control, providing important guidance on the limits of HMRC's information-gathering powers in transfer pricing disputes.

June 08, 2026: HMRC Issues Detailed Guidance on Revised Capital Gains Tax Anti‑Avoidance Framework for Share Exchanges and Corporate Restructurings[23]

The UK tax authority, HM Revenue & Customs (HMRC), expanded its Capital Gains Manual with guidance explaining the operation of revised anti‑avoidance measures affecting share exchanges, company reconstructions, and certain collective investment scheme transactions. The changes, announced in the 2025 Autumn Budget and enacted through Finance Act 2026, took effect on November 26, 2025, and are intended to strengthen HMRC’s ability to challenge arrangements designed primarily to obtain unwarranted capital gains tax advantages. A new appendix, CG‑APP20, replaces most of the earlier provisional guidance and clarifies how the updated rules apply to provisions in the Taxation of Chargeable Gains Act 1992, including share-for-share exchanges, reconstruction transactions, and business transfers. HMRC explains that while genuine tax deferral remains permissible, the revised rules target arrangements where securing a tax benefit is a main objective, providing greater clarity on enforcement and transitional treatment for earlier clearance applications.

June 12, 2026: UK Court of Appeal Clarifies Application of Exit Tax Rules to EU Relocations[24]

In Panayi and Redevco v HMRC [2026] EWCA Civ 744, the UK Court of Appeal considered whether the UK's exit tax rules were compatible with the European Union (EU) freedom of establishment principle in circumstances where taxpayers relocated from the UK to another EU member state before Brexit. While the Court affirmed the UK's right to tax unrealized gains accrued during periods of UK residence, it found that requiring immediate payment of the resulting tax liability was inconsistent with EU law. To address this, the Court interpreted the legislation to permit payment of the exit tax in five equal annual installments, consistent with Court of Justice of the European Union (CJEU) jurisprudence on proportionality. The Court also rejected taxpayers' argument that payment should be deferred until the underlying assets were actually disposed of, concluding that a five-year installment mechanism provided sufficient relief. The decision provides further guidance on applying EU law principles to pre-Brexit migrations and on interpreting UK tax legislation in that context.

June 23, 2026: UK Proposes Amendments to Capital Gains Tax Gift Holdover Relief[25]

The UK government announced proposed revisions to capital gains tax gift holdover relief provisions as part of a recently published policy paper and accompanying draft legislation. The proposals cover gifts of shares or securities in a personal trading company, a holding company of a trading group, and certain unlisted shares or securities. Under the draft provisions, holdover relief would be restricted where the company holds assets that qualify for the Substantial Shareholding Exemption (SSE) or are subject to the Intangible Fixed Assets (IFA) regime, unless those assets are used for the purposes of the company's or group's trade. The proposed measure is intended to reinstate the level of relief available before the introduction of the SSE and IFA regimes. The amendments are expected to be included in the Finance Bill and, if enacted, will take effect on April 06, 2027.

June 16, 2026: UK Seeks Stakeholder Feedback on New Reporting Framework for Multinational Cross-Border Related-Party Transactions[26]

The UK tax authority, HM Revenue & Customs (HMRC), launched a technical consultation on a proposed International Controlled Transactions Schedule (ICTS), which would require qualifying multinational groups to disclose standardized information annually about their cross-border-related-party transactions. The initiative is designed to strengthen HMRC’s ability to assess transfer-pricing risks through data-driven analysis, improve compliance monitoring, and make tax inquiries more targeted and efficient. Subject to implementation, the reporting requirement is expected to apply to accounting periods beginning on or after January 01, 2027. HMRC is seeking industry feedback on the draft regulations, reporting framework, and disclosure template, while aiming to balance enhanced transparency with manageable compliance obligations for businesses.

June 10, 2026: UK Seeks Feedback on Measures To Reduce Double Tax Burden for Residents Linked to Overseas Hybrid Entities[27]

The UK's tax authority, HM Revenue & Customs (HMRC), opened a public consultation on proposed reforms to address unintended double taxation faced by UK-resident individuals who hold interests in certain overseas entities, particularly US Limited Liability Companies (LLCs) and other reverse hybrid structures. The issue arises because some entities are treated differently for tax purposes across jurisdictions, leading to cases in which the same income can be taxed more than once. HMRC seeks input from affected individuals, businesses, investors, and professional advisers to better understand the scale of the problem and to gather views on potential legislative changes that could align tax treatment and reduce excessive tax liabilities caused by cross-border classification mismatches. The consultation will remain open until July 31, 2026, thereafter, the government will consider responses before deciding on any reforms.

June 23, 2026: UK Government Unveils Broad Tax Reform Agenda To Streamline Administration and Enhance Compliance[28]

The UK government outlined a wide-ranging program to modernize the country's tax and customs framework, with Treasury Minister Dan Tomlinson presenting the plans to Parliament as part of ongoing efforts to make the system simpler, more efficient, and easier for taxpayers and businesses to navigate. The initiative includes reviewing employee travel and subsistence reimbursement rates, seeking ways to accelerate tax payment processes for self-assessment taxpayers, modernizing PAYE settlement arrangements, examining the taxation of company distributions and overseas hybrid entities, updating VAT rules affecting online marketplaces and property transactions, introducing a simplified investment savings product aimed at first-time investors, and strengthening savings incentives. The government also intends to improve customs and duty procedures while enhancing HMRC's effectiveness in tax administration and revenue collection.

June 09, 2026: UK Introduces Customs Reforms for Digital Carnets, Postal Imports, and Off-Site Border Facilities[29]

The UK published the Customs (Miscellaneous Amendments) Regulations 2026 (SI 2026/605), introducing a range of customs administration changes. Key measures include permitting the use of digital carnets for customs declarations, extending bulk customs declaration arrangements for imported postal packets across the UK, and enabling HMRC to require port operators to provide off-site facilities for customs formalities where on-site space is insufficient. The regulations also update the rules governing interest on import duty liabilities arising from customs non-compliance or declaration amendments.

June 17, 2026: UK Supreme Court Rules on Tax Treatment of Profit Allocations in Mixed-Member LLP Structures[30]

The UK Supreme Court, in HMRC v HFFX LLP [2026] UKSC 17, held that partnership profits must be allocated according to the partners’ legal profit-sharing rights for the relevant accounting period and cannot be recharacterized solely because a corporate member subsequently distributes its profits to individual members. However, the Court concluded that amounts later received by individual members under the LLP’s deferred remuneration arrangement constituted taxable income. The judgment provides significant guidance on the taxation of mixed-member LLPs and deferred profit allocation arrangements.

Hong Kong

June 12, 2026: Hong Kong Moves To Expand Tax Concessions for Funds and Family Investment Vehicles[31]

Hong Kong introduced a Bill proposing significant enhancements to the preferential tax regimes for privately offered funds, family-owned investment holding vehicles (FIHVs), and carried interest arrangements. The proposed measures expand the definition of a fund and the scope of qualifying investments eligible for tax concessions, remove the existing 5% threshold applicable to incidental transactions, and provide more flexible tax treatment for special purpose entities and family-owned special purpose entities. The Bill includes refinements to the carried interest regime and introduces tax reporting and economic substance requirements under the unified fund tax regime. The proposed changes form part of Hong Kong's broader efforts to strengthen its position as an international asset and wealth management center and attract greater fund and family office activity to the jurisdiction.

Please refer to A&M Tax Alerts[32] for detailed analysis

June 12, 2026: Hong Kong Revises Guidance on GIR Filing Framework[33]

Hong Kong's Inland Revenue Department issued a supplementary user guide for preparing the GloBE Information Return (GIR), to be read together with the OECD's GIR XML Schema and User Guide. In-scope MNE groups can now upload test GIR data files to the Pillar Two Portal for validation testing.

June 17, 2026: Hong Kong Enhances Regulatory Framework for the Automatic Exchange of Information[34]

Hong Kong approved legislative amendments to reinforce its Automatic Exchange of Information (AEOI) regime, in line with OECD recommendations on tax transparency. The revised framework introduces new compliance obligations for reporting financial institutions, including mandatory registration requirements with the Inland Revenue Department and enhanced due diligence record-retention standards. The amendments also increase penalties for non-compliance, reflecting a stronger enforcement approach to AEOI requirements. The revised framework will take effect on January 1, 2027.

India

June 01, 2026: Supreme Court Affirms GST on Full Stake Value in Online Gaming and Gambling[35]

In a landmark ruling, the Supreme Court held that online gaming, fantasy sports, casinos, and similar activities involving pooled stakes constitute actionable claims arising from betting and gambling for GST purposes. The Court ruled that GST is payable on the entire amount of stake contributed by players, rather than only on the platform fee or commission retained by operators. It further held that online gaming companies function as principal suppliers, not merely intermediaries, given their control over game operations, prize pools, and player wallets. The Court also upheld the constitutional validity of the GST framework applicable to such transactions and held that the 2023 amendments clarifying valuation and collection provisions operate retrospectively.

June 05, 2026: India Provides Tax Relief for FIIs and BIS Investing in Government Securities[36]

India introduced a tax exemption regime for Foreign Institutional Investors (FIIs) [now Foreign Portfolio Investors (FPIs)] and the Bank for International Settlements (BIS) with respect to investments in specified government securities. Under the Income-tax (Amendment) Ordinance, 2026, issued on June 05, 2026[37], interest income and capital gains derived from such securities will no longer be subject to tax, replacing the prior tax treatment applicable to these income streams. The exemption is available subject to prescribed information reporting requirements and is limited to FIIs/FPIs and the BIS, with Non-Resident Indians (NRIs) remaining outside its scope. The measure has been granted retrospective effect from April 1, 2026.

June 18, 2026: Delhi High Court Holds EY US Secondment Arrangements Taxable as Fees for Included Services[38]

The Delhi High Court, in Ernst & Young US LLP, held that, where EY US retained ‘lien’ and overall control over seconded employees, reimbursement of salary by Indian network entities constitutes Fees for Technical Services (FTS). The Court observed that, absent termination rights for the Indian entities, the seconded personnel continued to be employees of EY US. Further, relying on the ruling in Centrica India Offshore (P.) Ltd., the Court held that imparting technical know-how and expertise satisfies the ‘make available’ condition and qualifies as FTS. The Court also clarified that a cost-to-cost reimbursement without any markup does not preclude FTS characterization. Issues relating to overseas services were remanded for further factual examination.

Please refer to A&M Tax Alert[39] for detailed analysis.

June 25, 2026: Mumbai ITAT Adopts Strict Interpretation of Demerger Provisions[40]

The Mumbai Income Tax Appellate Tribunal (ITAT), in Sterling Holiday Resorts Ltd. v. DCIT, denied tax-neutral demerger benefits and the carryforward of losses under section 72A, holding that the transaction failed to satisfy the statutory conditions of a ‘demerger’ under section 2(19AA) of the Income-tax Act, 1961. The ITAT emphasized that the prescribed conditions must be strictly complied with and cannot be relaxed based on the transaction’s commercial substance.

Please refer to A&M Tax Alert[41] for detailed analysis.

Japan

June 16, 2026: Japan Supreme Court Holds Cross-Currency Transactions Give Rise to Taxable FX Gains[42]

Japan's Supreme Court ruled that foreign exchange (FX) gains or losses are realized for tax purposes when a foreign currency is used to acquire another foreign currency or a foreign-currency-denominated security. The Court held that the yen-equivalent value of the acquired asset at the time of the transaction constitutes the amount received under the Income Tax Act and that any difference between that value and the yen cost of the foreign currency used gives rise to taxable income. Rejecting the taxpayer's argument that gains remain unrealized until conversion back into Japanese yen, the Court found that the economic value of the foreign currency is fixed upon exchange or acquisition. In a supplementary opinion, several judges noted that the absence of specific statutory provisions governing FX gains and losses creates uncertainty and suggested that legislative reform may be warranted.

Malaysia

June 26, 2026: Malaysia Extends Stamp Duty Disclosure Relief Program and Penalty Waiver Window[43]

The Inland Revenue Board of Malaysia (IRB) announced a six-month extension of the Special Voluntary Disclosure Program (SVDP) for stamp duty, allowing taxpayers to complete the stamping and payment of stamp duty for eligible instruments until December 31, 2026. Under the extended program, instruments executed between January 01, 2023, and December 31, 2025, may benefit from a full waiver of late-stamping penalties, provided the applicable stamp duty is paid within the SVDP period. The IRB also confirmed that the penalty waiver will be granted automatically, without a separate application, except in cases involving fraud. Additionally, instruments disclosed and stamped under the SVDP will not be selected for stamp duty audits, although the IRB may continue to review instruments outside the scope of the program.

Singapore

June 04, 2026: Singapore Clarifies Transfer Pricing Treatment of Share-Based Compensation from YA 2026[44]

The Inland Revenue Authority of Singapore (IRAS) clarified the transfer pricing treatment of share-based compensation (SBC) costs for intra-group service arrangements applying a cost-plus methodology. Effective from YA 2026, although incurred, uncharged, and notional SBC costs should continue to be included in the transfer pricing cost base for determining the arm’s length mark-up, taxpayers may exclude uncharged and notional SBC costs from the final service income charged to related parties. This change is expected to reduce potential transfer pricing mismatches for Singapore-based service providers operating under cost-plus models.

Please refer to A&M Tax Alert[45] for detailed analysis.

Thailand

June 16, 2026: Thailand Approves Participation in the GloBE Information Exchange Framework[46]

The Thai Cabinet authorized the signing of the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) under Pillar Two of the OECD/G20 Inclusive Framework's Two-Pillar Solution. The Global Anti-Base Erosion (GloBE) Model Rules require the annual filing of a GloBE Information Return (GIR), and the GIR MCAA facilitates the automatic exchange of such information with relevant jurisdictions as a Qualifying Competent Authority Agreement under the GloBE Model Rules. The first exchange of GIR information with partner jurisdictions is expected to commence by December 2027.

June 16, 2026: Thailand Approves Additional Tax Measures To Support Businesses and Digital Transformation[47]

Thailand's Cabinet approved, in principle, the issuance of draft Royal Decrees under the Revenue Code. The measures include: (i) a double tax deduction for qualifying expenditures related to e-Tax Invoice and e-Receipt and e-Withholding Tax systems, including certain information system assessment costs; (ii) an extension of the reduced 1% withholding tax rate for qualifying payments made through the e-Withholding Tax system; and (iii) extended tax deductions for eligible donations made through the e-Donation system for education and sports purposes. The measures relating to e-Tax systems and e-Withholding Tax will apply from January 01, 2026, to December 31, 2027. These measures are intended to enhance business liquidity, encourage adoption of electronic tax systems, and further support Thailand’s digital economy initiatives.

June 29, 2026: Thailand Restructures Customs Reward Regime While Maintaining Enforcement Incentives[48]

Thailand's Customs Department issued a new Notification on Informer and Officer Rewards, effective June 30, 2026, replacing the previous 2017 framework. The notification introduces a more structured approach to allocating rewards among customs officers involved in seizure, investigation, and supporting activities, while limiting eligibility for certain reward payments to operational-level officials. However, the fundamental reward regime remains largely unchanged, including informer rewards and officer rewards of up to 20% in qualifying cases, rewards of up to 10% for additional duty assessments, and a maximum payout cap of THB five million per case. Because the reform primarily changes how rewards are distributed among customs personnel rather than reducing the rewards themselves, customs officers continue to have financial incentives to identify non-compliance and recover underpaid duties, suggesting that businesses should expect continued customs scrutiny in areas such as valuation, tariff classification, origin claims, royalties, and licensing compliance.

June 26, 2026: Thailand Issues First Export Licensing Framework Under New National Control List[49]

Following the issuance of Thailand's first National Control List in May 2026 under the Trade Controls on Weapons of Mass Destruction Related Items Act B.E. 2562 (2019), the Ministry of Commerce issued two notifications on June 30, 2026 establishing export licensing requirements and licensing procedures for dual-use items under Category 0 (nuclear-related goods). The notifications require exporters and re-exporters of specified Category 0 items to obtain a license from the Department of Foreign Trade and set out the applicable application procedures, approval criteria, and documentation requirements. The licensing requirement takes effect on July 30, 2026, and represents the first phase of Thailand's implementation of a licensing-based export control regime, reflecting the country's efforts to strengthen strategic trade controls and align its export control framework with international non-proliferation standards.

Vietnam

June 10, 2026: Vietnam Issues Guidance on CbC Reporting and Automatic Information Exchange[50]

Vietnam's Tax Department clarified compliance requirement for Country-by-Country (CbC) reporting under the Multilateral Competent Authority Agreement on the Automatic Exchange of CbC Reports (CbC MCAA). The letter explains that, where a Vietnamese taxpayer’s Ultimate Parent Entity (UPE) is located overseas, is required to file a CbC Report under the regulations of its jurisdiction of residence, and falls within the scope of exchange under the CbC MCAA with the countries and territories specified in the letter, the tax authority will receive the CbC Report via automatic exchange of information mechanism under the international tax agreements to which Vietnam is a party and will not receive CbC Reports submitted by taxpayers in paper form or any other methods. This approach could reduce administrative burden for CbC reporting compliance.

United Arab Emirates

June 08, 2026: UAE Introduces Flexible Data Storage Rules Under Updated E‑Invoicing Guidelines[51]

The UAE Ministry of Finance issued Version 1.1 of its Electronic Invoicing Guidelines on June 1, 2026, allowing businesses to store e‑invoicing records either within or outside the UAE, provided the records can be made available to the Federal Tax Authority upon request. The updated guidance also clarifies the treatment of advance payments and retention amounts under the PINT‑AE billing specifications.

Please refer to A&M Tax Alert[52] for detailed analysis.

Bahrain

June 01, 2026: Bahrain Releases Transfer Pricing Guidance for Domestic Minimum Top-Up Tax[53]

Bahrain's National Bureau for Revenue (NBR) issued Version 1.0 of its DMTT Transfer Pricing Guide, outlining the transfer pricing framework applicable to in-scope multinational groups under the Domestic Minimum Top-up Tax (DMTT) regime. The guide aligns with OECD transfer pricing principles and introduces Local File and Master File documentation requirements for covered entities.

Please refer to A&M Tax Alert[54] for detailed analysis.

Australia

June 26, 2026: Australia Introduces Significant Tax and Investment Reforms[55]

Australia's Parliament enacted the Treasury Laws Amendment (Tax Reform No. 1) Bill 2026, which introduces significant changes to the country's capital gains tax (CGT) and housing tax framework. The Bill replaces the existing 50% CGT discount for individuals, trusts, and partnerships with an inflation-based cost base indexation mechanism, introduces a 30% minimum effective tax rate on realized capital gains, and tightens negative gearing rules for residential property investments. It also includes integrity measures targeting discretionary trust arrangements and high-net-worth structures, alongside personal tax relief measures such as a non-refundable Working Australians Tax Offset and a standard deduction for work-related expenses.

June 25, 2026: Australia Introduces Bill for Loss Carrybacks and Permanent Small Business Asset Write-Off[56]

Australia introduced the Treasury Laws Amendment (Tax Reform No. 2) Bill 2026, advancing measures designed to strengthen business cash flow and support investment. A key proposal would permit eligible companies to carry back current-year tax losses against taxable profits of earlier years, generating a refundable tax offset and providing liquidity support during challenging economic periods. The Bill also seeks to make the AUD 20,000 instant asset write-off a permanent feature of the tax system for small business entities with annual turnover below AUD 10 million, allowing immediate deductions for qualifying depreciating assets. Additionally, the proposed legislation introduces an income tax exemption for certain employment income earned from PNG Chiefs Limited, a Papua New Guinea-based National Rugby League franchise, to ensure consistent tax treatment for affected employees.

• On June 01, 2026, the United States announced adjustments to its Section 232 metals tariff regime, retaining the 50% tariff on most imported steel, aluminum, and copper products while expanding eligibility for a temporary 15% tariff rate on certain industrial and agricultural equipment. Effective June 08, 2026, the measures extend reduced-rate treatment for additional machinery, including mobile industrial equipment such as bulldozers and forklifts, through December 31, 2027. The proclamation also allows eligible capital equipment containing at least 85% US-origin steel or aluminum by weight to qualify for a lower 10% tariff rate, encouraging domestic sourcing. The administration stated that the temporary relief aims to support near-term investment and strengthen the US industrial base, while maintaining broader protections for core metals and derivative products. [57]
• On June 03, 2026, Canada responded to the US Trade Representative's (USTR) proposed Section 301 tariffs, reaffirming its commitment to combating forced labor in global supply chains while highlighting protections available under the USMCA. The proposed measures stem from a USTR investigation that found Canada among six economies with inadequate enforcement of existing bans on imports produced with forced labor. As a result, Canada may face an additional 10% tariff on non-exempt products. However, the proposal specifically exempts ‘USMCA-compliant goods,’ reducing the potential impact on integrated North American trade. Public consultations on the proposed tariffs are underway, with hearings scheduled for July 07, 2026. [58]
• On June 18, 2026, the US Trade Representative (USTR) launched a Section 301 investigation into Germany’s pricing policies for innovative pharmaceutical products to assess whether they are ‘unreasonable or discriminatory’ and restrict US trade. The USTR cited concerns that these policies may reduce revenues and investment in drug innovation. Public comments are invited until August 10, 2026, with a hearing scheduled for September 22, 2026. A related USTR press release was issued on June 18, 2026.[59]
• On June 16, 2026, the European Parliament approved two regulations implementing tariff-related commitments under the EU-US Joint Statement of August 21, 2025. The measures eliminate tariffs on all US industrial goods, provide preferential market access for selected US agricultural and seafood products, and extend tariff-free treatment for US lobster imports, including processed lobster products. The regulations also include safeguard provisions that enable the European Commission to suspend trade preferences if imports harm EU industries or if the United States does not meet its obligations. The regulations covering industrial, agricultural, and seafood products remains in force until December 31, 2029, unless renewed, while the lobster regulation extends tariff-free imports with retroactive effect from August 01, 2025. These measures aim to strengthen transatlantic trade relations while protecting key EU economic interests.[60]
• On June 15, 2026, the US Supreme Court declined to review a lower court ruling that upheld the US Trade Representative's (USTR) authority to modify Section 301 tariffs on Chinese imports introduced in 2018 and 2019. By refusing to review the case HMTX Industries, LLC, et al. v. United States, et al., the Court left intact the Federal Circuit's September 25, 2025, decision, which held that the USTR was authorized under the Trade Act of 1974 to adjust tariffs in response to China's retaliatory actions. The ruling also rejected claims that the tariff changes exceeded statutory authority or violated procedural requirements, ensuring that the ‘List 3’ and ‘List 4A’ tariffs remain valid.[61]
• Effective May 01, 2026, the United States updated Section 232 tariff treatment for certain automobile parts, wood products, and civil aircraft components imported from Chinese Taipei, consistent with commitments under a January 15, 2026, investment Memorandum of Understanding. Auto parts with a base tariff of 15% or higher will no longer face additional Section 232 duties, while those with lower base rates will face a combined 15% tariff. Eligible auto parts used in US vehicle production or repair may qualify for reduced or zero additional duties through self-certification. The changes also impose a 15% additional duty on certain wood products, while qualifying civil aircraft components are exempt from derivative Section 232 duties on steel, aluminum, and copper, providing targeted relief for key sectors. [62]
• The UK introduced the Customs (Tariff and Miscellaneous Amendments) (No. 4) Regulations 2026 (SI 2026/572), effective July 01, 2026, to implement Version 1.32 of the Tariff of the United Kingdom (dated May 25, 2026). The changes increase the standard import duty rate to 50% for specified steel products and introduce an excepted goods framework under which the 50% rate may apply instead of certain preferential tariff rates.[63]