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14 April 2026 Global Tax Policy and Controversy Watch | April 2026 edition On 18 March 2026, the European Commission (EC) released its proposal for a Regulation on the 28th Regime Corporate Legal Framework — "EU Inc." The EC proposes a harmonized corporate legal framework, introducing in the national legal orders of all European Union (EU) Member States a new legal form, a limited liability company referred to as an "EU Inc." The proposal will now be subject to review and negotiation by EU Member States and the European Parliament. On 18 March 2026, the EC launched a consultation on e-invoicing. The consultation aims to ensure that relevant stakeholders can provide their views, evidence and experience regarding the key challenges and opportunities for the revision of the e-invoicing Directive 2014/55/EU. The consultation closes at midnight on 10 June 2026. Luxembourg's Parliament adopted a law on 19 March 2026, transposing EU Directive 2023/2226 (DAC8) into national tax law, mandating reporting and exchange of information on crypto assets. Effective retroactively from 1 January 2026, the automatic exchange of information now includes life insurance income and certain advance cross-border rulings. This expansion requires stakeholders to update customer onboarding, compliance and data reporting processes to meet the new regulatory framework. Outlining value-added tax (VAT) systems in 153 jurisdictions, the 2026 edition of our annual reference book, Worldwide VAT, GST and Sales Tax Guide, is now available in an interactive map format (as well as to download as a pdf) on ey.com.
The 27th Advance Pricing and Mutual Agreement Program report (Announcement 2026-08) shows the US Internal Revenue Service received 178 Advance Pricing Agreement (APA) requests in 2025, up from 169 in 2024. However, total executed APAs dropped to 110 from 142. The median completion time increased to 41.6 months. Although staffing and budget cuts affected the number of APAs executed, the program remains vital for transfer pricing certainty. Australian Taxation Office (ATO) released a Decision Impact Statement on 19 March 2026 following the High Court ruling in Commissioner of Taxation v PepsiCo Inc. The ATO emphasized the decision was based on specific facts at issue in the case and does not restrict the Commissioner's ability to challenge intellectual property (IP) arrangements, including embedded rights in payments. The ATO will continue scrutinizing pricing, economic substance and evidence in IP cases. The ATO also stated the Court's finding that Diverted Profits Tax did not apply was based on critical facts that were unique to PepsiCo and would have limited application in other cases. Amid other changes, branches of foreign entities and permanent establishments in Colombia became subject to Net Wealth Tax for assets exceeding COP10.47b as of 31 March 2026, with compliance deadlines on 30 April and 1 June 2026. Transitional relief measures offer reduced penalties and interest for past-due tax, customs and foreign-exchange obligations, encouraging taxpayers to regularize filings and payments by 30 April 2026 to potentially benefit from these concessions. On 29 January 2026, the Ghana Court of Appeal ruled in Republic v. Commissioner-General, Ghana Revenue Authority, clarifying that taxpayers can claim refunds for value-added tax (VAT) overpayments under the VAT Act, even if the taxpayers are not exporters. The Court affirmed taxpayers' right to seek a mandamus order to compel timely processing of refund claims by the Commissioner General. Multinational enterprises should review their VAT positions and consider filing for tax refunds. Kenya Tax Appeals Tribunal ruled on 23 February 2026 that the principal portion of written-off loans is not deductible for income tax, aligning with Kenya Revenue Authority's stance. The Tribunal classified the principal loan amount as a capital asset under International Financial Reporting Standard (IFRS) 9: Financial Instruments, overturning prior rulings that allowed bad debt deductions. This affects financial institutions from 2018 onward, creating uncertainty in tax treatment of loan write-offs. Financial entities should reassess their tax positions and monitor ongoing developments closely. On 17 March 2026, the Mauritius Revenue Tribunal held that the four-month statutory period for determining objections excludes the filing date and that a calendar month runs from one date to the corresponding date in the next month, effectively extending the Registrar General's timeframe. The Tribunal also ruled that formal notification within the statutory period is not required, potentially affecting timelines under other tax statutes and increasing uncertainty for affected taxpayers. Romania's Ministry of Finances issued Order No. 203 on 13 March 2026, detailing deferred tax presentation for entities under Law no. 431/2023, which introduced a 15% global minimum corporate tax. From the 2025 financial year, multinational and large domestic groups with revenues exceeding €750m can switch from applying Romanian Accounting Regulations to applying IFRS for statutory accounting purposes. Alternatively, companies subject to domestic top-up tax must disclose deferred taxes in financial statements per the Order of the Ministry of Finance No. 1802/2014. The IFRS option aids alignment for groups already using IFRS for consolidation. Swiss voters approved a major reform on 8 March 2026, replacing joint taxation of married couples with mandatory individual taxation for all taxpayers, effective by 1 January 2032 and affecting federal, cantonal and municipal tax filings. Payroll withholding and tax compliance processes will require significant updates, including recalibration of withholding tax tariffs and payroll systems, with transitional risks of over- or under-withholding.
Document ID: 2026-0865 | ||||
