GLOBAL TAX INTELLIGENCE
International and corporate tax developments.
Follow material tax changes around the world, with clear legal status and links to the original documents.
From the Intelligence desk.
Tax developments and analysis from Straxiom Intelligence. Browse by topic and country.
Malaysia · Administrative guidance
Malaysia updates foreign-capital-gains guidance
On 29 September 2026, Malaysia’s Inland Revenue Board issued revised guidance on foreign-capital-asset gains received in Malaysia, incorporating statutory extensions of conditional exemptions to 31 December 2030.
Malaysia · Administrative guidance
Malaysia compares Schedules 7A and 7B investment allowances
On 29 September 2026, Malaysia’s Inland Revenue Board issued Practice Note 3/2026 comparing the statutory investment allowances for manufacturing and agriculture with those for approved service projects.
Brazil · Enacted legislation
Brazil cuts local reinsurers’ CSLL and removes the IRPJ surtax
On 29 September 2026, Brazil published Law No. 15,525, introducing staged corporate-tax relief for Brazilian local reinsurance companies: a 9% CSLL rate and broader use of tax losses from 2027, followed by removal of the 10% IRPJ surtax from 2030.
Germany · Proposed legislation
Germany’s Annual Tax Bill reaches committee with Pillar Two and VAT-group changes
On 8 October 2026, Germany’s Bundestag referred the proposed Jahressteuergesetz 2026 to committees after its first reading, advancing changes to Pillar Two safe harbours, withholding relief, VAT groups, research incentives and multinational reporting.
Ireland · Enacted legislation
Ireland cuts standard capital gains tax rate to 31%
On 6 October 2026, Dáil Éireann passed Financial Resolution No. 3, reducing the standard capital gains tax rate in section 28(3) of the Taxes Consolidation Act 1997 from 33% to 31% for disposals on or after 7 October 2026.
Germany · Proposed legislation
Germany’s 2027 tax reform proposes data-centre and payroll changes
On 8 October 2026, Germany’s Bundestag referred the proposed Einkommensteuerreformgesetz 2027 to committees after its first reading, advancing changes to data-centre trade-tax allocation, payroll exemptions and income-tax bands.
Thailand · Consultation
Thailand consults on qualified refundable tax credit framework
On 6 October 2026, Thailand's Revenue Department opened a public consultation on principles for a proposed Qualified Refundable Tax Credits Act, with comments invited until 5 November.
France · Proposed legislation
France proposes three-month tacit tax ruling procedure
On 1 October 2026, the French Government tabled its 2027 Finance Bill, proposing a three-month tacit-acceptance procedure for tax ruling requests by businesses in specified tax-administration support programmes.
Poland · Enacted legislation
Poland enacts 60% fuel windfall tax with retrospective March 2026 coverage
On 1 October 2026, Poland published the Act of 18 September 2026 imposing a 60% tax on extraordinary liquid-fuel sale revenues for the period from 1 March 2026 to 31 March 2027. Most provisions commence on 1 November 2026.
United States · Administrative guidance
US IRS treats planned ETF portfolio conversions as taxable exchanges
On 28 September 2026, the US Treasury and Internal Revenue Service released Revenue Ruling 2026-20, treating a planned contribution and redemption through an exchange traded fund as a taxable securities exchange, alongside Notice 2026-62 on potentially abusive investment-fund strategies.
United States · Administrative guidance
US revises staking safe harbour for digital-asset investment trusts
On 6 October 2026, the IRS released Revenue Procedure 2026-20, revising the conditions under which qualifying digital-asset investment trusts can stake their assets without losing their federal income tax classification.
New Zealand · Proposed legislation
New Zealand omnibus tax bill proposes FBT, investment and multinational changes
On 10 September 2026, New Zealand introduced the Taxation (Annual Rates for 2026–27, FBT Simplification, Foreign Investment Funds, and Remedial Measures) Bill.
Portugal · Proposed legislation
Portugal’s 2027 Budget Bill extends R&D and business tax incentives
On 8 October 2026, Portugal submitted Proposal of Law 110/XVII/2 for the 2027 State Budget, proposing extensions and adjustments to several business-tax incentives from 1 January 2027.
Germany · Court decision
Germany carries demerger holding periods into real estate transfer tax relief
On 8 October 2026, Germany’s Federal Fiscal Court published judgment II R 5/23, allowing a company receiving shares through a full demerger to inherit its predecessor’s holding period for group real estate transfer tax relief on a later merger.
United Arab Emirates · Administrative guidance
UAE clarifies free-zone status across corporate tax, VAT and excise
On 2 October 2026, the UAE Federal Tax Authority issued TAXP010, explaining why free-zone and designated-zone status must be checked separately for corporate tax, VAT and excise tax.
Finland · Proposed legislation
Finland proposes interest relief for critical infrastructure projects
On 9 October 2026, Finland’s Parliament published Government Proposal HE 227/2026 vp, dated 8 October, proposing additional interest deductions for infrastructure essential to security of supply.
Norway · Proposed legislation
Norway’s 2027 budget: R&D restrictions and business tax proposals
On 2 October 2026, Norway’s Ministry of Finance recommended its 2027 tax budget bill, proposing R&D restrictions, aquaculture tax changes, Pillar Two powers and wider business tax measures.