Issue 79 - August 2026
The past quarter brought a notable wave of international tax developments, underscoring how quickly jurisdictions are reshaping compliance frameworks, transparency standards and cross-border tax rules. Tax authorities continue to focus on tighter documentation, expanded transparency obligations and greater alignment with international initiatives.
Taken together, these developments show that international tax reform is moving on multiple fronts: authorities are tightening documentation and reporting expectations, applying closer scrutiny to ownership and substance, and revising structural rules that affect how multinational groups recognize income and losses, use tax attributes and manage cross-border tax exposure.
Key developments include:
- Argentina has revised its tax treaty-benefit documentation rules, adding stricter residence verification and sworn declarations for payers and foreign recipients.
- The EU has advanced a broad simplification package, including the Direct Taxation Omnibus Directive and a recast of the Directive on Administrative Cooperation, aimed at reducing administrative burdens, refining DAC6 and DAC7 reporting and strengthening information exchange.
- Germany continues to focus on disregarded and hybrid entities, including treaty access for US S corporations and the still-unresolved treatment of US disregarded entity structures for German dividend withholding tax relief.
- Greece has transposed DAC9 into domestic law, adopting standardized GloBE information return procedures and reinforcing Pillar Two reporting obligations.
- Malta has revised beneficial ownership reporting rules, requiring certain entities to reassess records and submit a new declaration form aligned with the EU’s developing anti-money laundering framework.
- Panama has introduced an economic substance regime for foreign-source passive income, marking a significant departure from its traditional territorial model.
- Switzerland has approved extending the tax loss carryforward period from seven to 10 years, giving businesses more time to use losses arising from longer investment, development or recovery cycles.
- The UAE has clarified the connected-person rules, emphasizing substance-based assessments of authority and decision-making.
- The UK has announced a move to a mandatory foreign permanent establishment exemption, a structural shift in how multinational groups manage branch profits and losses.
For multinational groups, the practical takeaway is to track not only new reporting and documentation obligations, but also changes that may affect entity classification, substance analysis, branch taxation and the use of losses. These developments underscore the importance of keeping governance, documentation and reporting frameworks current as global tax rules continue to evolve.
