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International
  • Bosnia and Herzegovina: The Republic of Srpska has revised its profit tax rules to clarify the definition and tax treatment of a permanent establishment (PE). For example, a construction, installation or assembly site (including related supervisory activities and/or the exploration of natural resources) constitute a PE if the activity lasts longer than 12 months. Profits attributable to a PE must be calculated as if the PE were a separate and independent entity, taking into account for functions performed, assets used and risks assumed.
  • British Virgin Islands: The tax authorities published a notice announcing the transition to a new reporting system for the economic substance requirements. Beginning 2 January 2026, the Beneficial Ownership Secure Search System is replaced by the Virtual Integrated Registry Regulatory General Information Network.
  • Cambodia: The General Department of Taxation confirmed on 2 January 2026 that the implementation of the capital gains tax on the disposal of real property is delayed until 1 January 2027. The tax applies to other covered assets from 1 January 2026.
  • Cameroon: The Finance Law for 2026, which generally applies as from 1 January 2026, introduces significant economic presence (SEP) rules, clarifies the taxation of foreign airlines and shipping companies and establishes a framework for the mutual assistance in tax recovery with foreign tax administrations. Under the SEP rules, foreign operators that provide services or engage in transactions with users in Cameroon via digital platforms are deemed to have a taxable economic presence if they exceed XAF 50 million in annual turnover or have more than 1,000 users in Cameroon, regardless of their physical presence in the country. Such operators must register with the Cameroon tax authorities. Foreign airlines and shipping companies are subject to Cameroon corporate income tax on profits generated in the country, unless otherwise provided in an applicable tax treaty or other agreement.
  • Cayman Islands:
    • The International Tax Co‑operation (Economic Substance) Act (2026 Revision) published on 5 February 2026 consolidates and updates the domestic economic substance framework, aligning with OECD and EU standards for geographically mobile business activities. Originally introduced in 2019, the updates set out the procedures for the authorities to enforce the measures through compliance reviews, administrative penalties and information exchange.
    • Regulations published on 27 November 2025 implement the OECD's Crypto-Asset Reporting Framework (CARF). As from 1 January 2026, crypto-asset service providers based in the Cayman Islands must identify reportable users, conduct CARF-specific due diligence and collect valid self-certifications. Existing providers must notify the Cayman authorities by 30 April 2026; new providers must register by 31 January 2027.
  • China: The exemption from corporate income tax and VAT for bond interest income obtained by foreign institutional investors from investing in the domestic Chinese bond market, previously set to expire on 31 December 2025, has been extended to apply through 31 December 2027.
  • Colombia: On 29 January 2026, the Constitutional Court suspended two recent decrees: one declaring an economic emergency (22 December 2025) and another introducing several temporary taxes (29 December 2025).
  • European Union:
    • The Economic and Financial Affairs Council announced on 17 February 2026 that it has added two countries—Turks and Caicos and Vietnam—to the EU list of noncooperative jurisdictions and removed Fiji, Samoa and Trinidad and Tobago. There are now 10 jurisdictions on the list: American Samoa, Anguilla, Guam, Palau, Panama, Russia, Turks and Caicos, US Virgin Islands, Vanuatu and Vietnam.
    • The European Commission has issued letters of formal notice to EU member states that have not fully transposed DAC 8 (exchange of information on crypto-assets) and DAC 9 (GIR information exchange):
      • DAC 8 noncompliant countries: Belgium, Bulgaria, Czech Republic, Cyprus, Estonia, Greece, Malta, Luxembourg, Netherlands, Poland, Portugal and Spain;
      • DAC 9 noncompliant countries: Belgium, Bulgaria, Czech Republic, Greece, Cyprus, Malta, Netherlands, Portugal, Romania and Sweden (see items below on Romania and Sweden).
    • Member states have two months to respond and complete the required action.
      • On 1 January 2026, Bulgaria adopted the euro as its currency, replacing the lev, bringing the number of EU member states in the eurozone to  21.
  • Georgia: Effective 1 January 2026, dividends paid by a resident company to a resident individual, non-entrepreneurial (non-commercial) company and nonresident company are exempt from withholding tax if the dividends are received by the distributing company from a qualifying financial institution and relate to profits arising as from tax year 2023.
  • Germany: The finance minister has renewed calls for the introduction of a digital tax on large global technology firms and an additional levy on international streaming services.
  • India: The Income-tax Act, 2025 will take effect on 1 April 2026. The Central Board of Direct Taxes is consulting on draft Income-tax Rules, 2026, which will replace the current rules dating from 1962.
  • Malawi: An 0%/5% minimum alternate tax on turnover applies from 31 December 2025 to companies with turnover exceeding MWK 5 billion and that have been in a continuous loss position for more than three years. Companies must pay the higher of the alternate tax or the 30% corporate tax.
  • New Zealand: Updated guidance on the Crypto-Asset Reporting Framework (CARF) that becomes effective on 1 April 2026 will require New Zealand-based reporting crypto-asset service providers to collect and report information about crypto-asset users operating through them, with initial reporting due on 30 June 2027 for the period 1 April 2026 to 31 March 2027.
  • OECD:
    • On 2 February 2026, the OECD released an updated edition of its Manual on Effective Mutual Agreement Procedures (MEMAP), expanding on the 2007 version. The MEMAP offers non-binding, comprehensive practical guidance to competent authorities and taxpayers on the effective conduct of the MAP, with the updated version including guidance developed based on administration of the BEPS Action 14 Minimum Standard peer reviews and steps jurisdictions can take to proactively prevent disputes.
    • Guatemala joined the Inclusive Framework on 12 January 2026 (see the Pillar Two update column).
    • The OECD announced on 4 December 2025 that 26 jurisdictions have committed to implementing the new international framework for the automatic exchange of information on offshore real estate. The following countries have signed on: Belgium, Brazil, Chile, Costa Rica, Finland, France, Germany, Gibraltar, Greece, Iceland, Indonesia, Ireland, Italy, Korea, Lithuania, Malta, New Zealand, Norway, Peru, Portugal, Romania, Slovenia, South Africa, Spain, Sweden and the UK.
  • Papua New Guinea: The Income Tax Act 2025, which became effective on 1 January 2026, includes a new 15% withholding tax on the repatriation of profits of nonresidents with a permanent establishment in the country and a provision allowing members of corporate groups to transfer losses to other group entities.
  • Philippines: A circular issued on 24 November 2025 indefinitely suspends field audits and related operations by the Bureau of Inland Revenue (BIR), except in designated situations. The suspension, which applies to all BIR offices involved in audit and field operations, will remain in place until lifted by the BIR Commissioner.
  • Poland: As from 1 January 2026, investment and pension funds from non-EU/EEA jurisdictions that are comparable to Polish and EU/EEA investment and pension funds are exempt from corporate income tax in Poland, as are self-managed investment funds.
  • Romania: DAC 9 was transposed into domestic law on 30 January 2026.  
  • Saudi Arabia: The government has extended the tax amnesty for an additional six months from 1 January 2026 to 30 June 2026. Based on guidelines published by the authorities, taxpayers are exempt from penalties for late payment or filing of tax returns and other tax law violations. To benefit from the initiative, taxpayers must be registered with the tax authorities, submit all tax returns and pay all tax due by the expiration of the amnesty. Originally introduced in March 2020, the amnesty has been extended several times.
  • Singapore: The Prime Minister and Minister for Finance delivered the Budget 2026 Statement on 12 February 2026. Balancing immediate support with long-term transformation, the budget reinforces Singapore’s resilience, competitiveness and future readiness. It underscores the imperative of embracing AI and advanced technologies as new growth drivers, while strengthening workforce capabilities and investing in the next generation to secure sustainable, long-term growth. Businesses can expect a comprehensive suite of measures to accelerate AI adoption, deepen digital transformation and expand internationalisation efforts. (Click here for BDO in Singapore’s analysis of the budget measures).
  • Slovak Republic: For tax periods starting on or after 1 January 2026, withholding agents are required to use a new notification form template for tax withholding and the transfer of tax collected by withholding.
  • Sweden: The Ministry of Finance presented a bill on 27 January 2026 that would implement the DAC 9 directive into domestic law and amend the country’s Pillar Two legislation to align Swedish law with international standards for tax transparency and cooperation.
  • Thailand:
    • The Revenue Department has announced an economic stimulus package for the tourism sector, particularly for hotel businesses. Eligible taxpayers can claim an additional 100% tax deduction for costs related to additions, alterations and renovations of their hotel properties (for more details on the incentive, see the tax alert prepared by BDO in Thailand).
    • A royal decree published on 10 February 2026 allows small and medium-sized enterprises to claim an additional 100% deduction for investments in digital tools and services, including the purchase, development or use of computer programs, hardware or smart devices. Specific requirements must be met to benefit from the deduction.
  • Trinidad and Tobago: Finance Bill 2025 introduces an annual commercial asset levy of 0.25% on the total asset value of licensed financial institutions and local insurance companies. Such entities must file annual returns, with penalties for noncompliance.
  • Turkiye: A presidential decree that applies as from 1 January 2026 reduces the digital services tax rate from 7.5% to 5%. The rate will drop to 2.5% on 1 January 2027.
  • United Arab Emirates: The UAE has updated both the 9% standard corporate tax regime and the 0% free zone regime. Ministerial Decisions No. 229 and 230 of 2025 expand qualifying activities for free zone relief, while Ministerial Decision No. 173 introduces depreciation adjustments for fair-valued investment property.
  • United Kingdom: On 9 February 2026, the UK tax authorities (HMRC) released guidance to help large and complex business groups in preparing and reviewing group structure information required for submission.
  • United States: On 12 February 2026, the Treasury Department and IRS released guidance on new restrictions to the clean energy tax credits enacted under the One Big Beautiful Bill Act. The guidance outlines how to determine whether electricity-producing qualified facilities, energy storage technologies, or eligible components receive material assistance from a prohibited foreign entity, which would render them ineligible for certain energy tax credits.
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