This e-newsletter gives you an overview of international tax developments being reported globally by KPMG member firms in the Europe and Africa Regions between 1 March and 31 March 2026.
International Tax Europe and Africa March 2026
For a full summary of global tax developments, visit kpmg.com/TaxNewsFlash.
To contact the International Tax Team email internationaltax@kpmg.com.
To register for the International Tax webcasts, click here.
Belgium
Belgium | |||
KPMG publications | Various tax topics | 26 March 2026 | Summary of recent tax developments. Read more |
Administrative and case law | Income tax | 25 March 2026 | European Court of Justice (ECJ) Rules Belgian Communal Tax on Non-Residents Discriminatory. Read more |
Proposed legislation | BEPS Pillar 2 | 24 March 2026 | New draft domestic top-up tax (DTT) return published for information purposes only. Read more |
Administrative and case law | Income tax | 23 March 2026 | Taxpayer properly included arm’s length intercompany royalties in computing innovation income deduction (IID) (court decision). Read more |
Proposed legislation | BEPS Pillar 2 | 20 March 2026 | Draft income inclusion rule (IIR) top-up tax return published for public consultation. Read more |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 18 March 2026 | Guidance on currency conversion for global minimum tax. Read more |
Cyprus
Cyprus | |||
Tax legislation approved and regulatory update | Indirect tax | 31 March 2026 | Amendments to Value Added Tax (VAT) laws addressing real property. Read more |
Tax legislation approved and regulatory update | Indirect tax | 27 March 2026 | Value Added Tax (VAT) and excise duty relief measures for electricity, motor fuels, and food. Read more |
Tax legislation approved and regulatory update | Various tax topics | 17 March 2026 | Comprehensive Tax Reform Introduced for 2026. Read more |
Tax legislation approved and regulatory update | Indirect tax | 03 March 2026 | Amendments to Value Added Tax (VAT) law relating to real property. Read more |
Czechia
Czechia | |||
Administrative and case law | Transfer Pricing | 25 March 2026 | Subsidiary deemed to be contract manufacturer of foreign parent company (Supreme Administrative Court (SAC) decision). Read more |
Administrative and case law | Indirect tax | 17 March 2026 | One-time transaction is not economic activity for Value Added Tax (VAT) registration purposes (Supreme Administrative Court decision). Read more |
Proposed legislation | Various tax topics | 12 March 2026 | Proposed amendments to electronic sales reporting (EET) system. Read more |
Tax legislation approved and regulatory update | Indirect tax | 12 March 2026 | Guidance on application of Value Added Tax (VAT) to immovable assets. Read more |
Administrative and case law | Indirect tax | 11 March 2026 | Tax authority discussion paper on claiming Value Added Tax (VAT) deduction in previous tax period through additional VAT return after receiving tax document. Read more |
KPMG publications | Various tax topics | 11 March 2026 | Overview of tax legislation valid in 2026. Read more |
Administrative and case law | Income tax | 11 March 2026 | Taxpayer must prove temporal connection between claimed expenses and relevant tax period (Supreme Administrative Court decisions). Read more |
Denmark
Denmark | |||
Administrative and case law | Tax compliance | 25 March 2026 | Danish Business Authorities (DBA) latest work and 2026 agenda for digital bookkeeping and e-invoicing Future default use of electronic invoicing (e-invoicing) for companies using registered bookkeeping system. Read more |
European Union
European Union | |||
Proposed legislation | Indirect tax | 30 March 2026 | Agreement to reform European Union (EU) Customs Code. Read more |
Administrative and case law | Indirect tax | 18 March 2026 | Court of Justice for the European Union (CJEU) Advocate General (AG) opinion on Value Added Tax (VAT) treatment of credit management in securitization structures (Finland). Read more |
Tax legislation approved and regulatory update | Various tax topics | 16 March 2026 | Updated State aid rules for sustainable transportation. Read more |
Administrative and case law | Indirect tax | 11 March 2026 | Court of Justice of the European Union (CJEU) referral of Spain for failure to transpose two Value Added Tax (VAT) directives. Read more |
Administrative and case law | Income tax | 11 March 2026 | Retroactive withholding tax exemptions under Interest and Royalties Directive (Court of Justice of the European Union (CJEU) judgment). Read more |
Administrative and case law | Indirect tax | 05 March 2026 | Court of Justice of the European Union (CJEU) confirms sale of in-game “gold” subject to Value Added Tax (VAT). Read more |
Administrative and case law | Income tax | 03 March 2026 | Court of Justice of the European Union (CJEU) decision on the compatibility of the Belgian CFC rules with the Anti-Tax Avoidance Directive. Read more |
Proposed legislation | Tax compliance | 03 March 2026 | Commissioner Wopke Hoekstra’s response to Members of the European Parliament (MEPs) on how the European Comission (EC) intends to simplify the Directive on administrative cooperation (DAC). Read more |
Proposed legislation | Various tax topics | 03 March 2026 | Call for evidence on upcoming tax omnibus proposal. Read more |
Administrative and case law | Income tax | 03 March 2026 | Prior Belgian controlled foreign company (CFC) rules incompatible with Anti-Tax Avoidance Directive (ATAD) (Court of Justice of the European Union (CJEU) judgment). Read more |
Finland
Finland | |||
Proposed legislation | BEPS Pillar 2 | 18 March 2026 | Proposed additional amendments to Pillar Two rules. Read more |
Gabon
Gabon | |||
KPMG publications | Various tax topics | 27 March 2026 | Gabon Finance Law 2026 includes mandatory electronic invoicing, other recent tax developments. Read more |
Germany
Germany | |||
Proposed legislation | Income tax | 30 March 2026 | Draft guidance on the principles of administration for the definition and establishment of permanent establishments (PE) in domestic and international Tax Law. Read more |
Proposed legislation | Various tax topics | 30 March 2026 | Framework concept for a new legal form for companies: Company with tied assets. Read more |
Administrative and case law | Income tax | 30 March 2026 | Federal Tax Court (I R 37/22): Requirements for the performance of a profit transfer agreement in a tax group. Read more |
Administrative and case law | Income tax | 30 March 2026 | Federal Tax Court (I R 40/23): Reduction in a shareholder's income in connection with a hidden contribution. Read more |
Administrative and case law | Income tax | 30 March 2026 | Federal Tax Court (I R 9/23): Relationship between crediting of the period of ownership and trade tax participation exemption (Privilege). Read more |
Administrative and case law | Indirect tax | 30 March 2026 | Federal Tax Court (II R 24/22): Unification of Shares for Real Estate Transfer Tax Purposes in Cases Where the Land-Owning Company Acquires Treasury Shares. Read more |
Tax legislation approved and regulatory update | Income tax | 30 March 2026 | Federal Ministry of Finance: New guidance on the capitalisation of fund establishment costs. Read more |
Administrative and case law | Income tax | 25 March 2026 | Failure to tax deemed capital gain on “hidden contribution” not a reduction in shareholder’s income, other tax developments. Read more |
Administrative and case law | Tax compliance | 24 March 2026 | Updated FATCA guidance. Read more |
Administrative and case law | Income tax | 23 March 2026 | Requirements for performance of profit transfer agreement in a tax group (Federal Fiscal Court decision). Read more |
Administrative and case law | Income tax | 06 March 2026 | Updated guidance on mutual agreement and arbitration procedures. Read more |
Administrative and case law | Tax compliance | 03 March 2026 | Updated CRS guidance. Read more |
KPMG publications | Indirect tax | 02 March 2026 | Reduction in Value Added Tax (VAT) base for pharmaceutical manufacturer discounts, other VAT developments. Read more |
Greece
Greece | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 19 March 2026 | Guidance on requirements for constituent entity notifications under Pillar Two rules. Read more |
Guernsey
Guernsey | |||
Administrative and case law | Tax compliance | 26 March 2026 | Updated FATCA and common reporting standard (CRS) guidance (Guernsey). Read more |
Iceland
Iceland | |||
Treaties | Income tax | 06 March 2026 | Income tax treaty with Saudi Arabia enters into force. Read more |
Italy
Italy | |||
Administrative and case law | Income tax | 16 March 2026 | Higher withholding tax rate on dividends paid to nonresidents held discriminatory under Treaty on the Functioning of the European Union (TFEU) (Supreme Court decision). Read more |
Administrative and case law | Indirect tax | 12 March 2026 | Taxpayer has right to claim Value Added Tax (VAT) refund directly from Treasury when customer involved in extended insolvency proceedings (Supreme Court decision). Read more |
Tax legislation approved and regulatory update | Indirect tax | 11 March 2026 | New guidance on recovery of input Value Added Tax (VAT) on special purpose vehicle (SPV) transaction costs in merger levered buyout (MLBO). Read more |
Jersey
Jersey | |||
Administrative and case law | Tax compliance | 11 March 2026 | Updated FATCA and common reporting standard (CRS) practical guides (Jersey). Read more |
Administrative and case law | Tax compliance | 10 March 2026 | Guidance on common errors in 2024 FATCA and common reporting standard (CRS) reporting (Jersey). Read more |
Kazakhstan
Kazakhstan | |||
Tax legislation approved and regulatory update | Income tax | 16 March 2026 | Updated list of countries not treated as controlled foreign companies (CFCs). Read more |
Luxembourg
Luxembourg | |||
Tax legislation approved and regulatory update | Income tax | 02 March 2026 | New carried interest tax regime enacted. Read more |
Malta
Malta | |||
Administrative and case law | Tax compliance | 10 March 2026 | Updated Automatic Exchange of Information guidance. Read more |
Proposed legislation | Indirect tax | 10 March 2026 | Excise duty on nicotine pouches. Read more |
Tax legislation approved and regulatory update | Indirect tax | 09 March 2026 | Extension of tax and duty relief on transfers of immovable property. Read more |
Administrative and case law | Tax compliance | 03 March 2026 | New self-compliance questionnaire (SCQ) for FATCA and common reporting standard (CRS) compliance monitoring. Read more |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 03 March 2026 | Exemption for local group members from filing GloBE information return (GIR) and related notifications. Read more |
Moldova
Moldova | |||
Proposed legislation | Indirect tax | 20 March 2026 | Consultations on draft legislation implementing multiple European Union (EU) excise directives. Read more |
Proposed legislation | Indirect tax | 09 March 2026 | Proposed additional increase in Value Added Tax (VAT) registration threshold. Read more |
Tax legislation approved and regulatory update | Transfer pricing | 09 March 2026 | Amendments to transfer pricing documentation rules. Read more |
Montenegro
Montenegro | |||
Tax legislation approved and regulatory update | Indirect tax | 23 March 2026 | Amendments to Value Added Tax (VAT) law enacted by parliament. Read more |
Netherlands
Netherlands | |||
KPMG publications | Various tax topics | 25 March 2026 | KPMG report: Shipping and offshore tax update (March 2026). Read more |
Administrative and case law | Income tax | 20 March 2026 | Tax authority letter clarifying effect of Supreme Court decision invaliding increased corporate income tax interest rates. Read more |
Administrative and case law | Income tax | 06 March 2026 | Royalty withholding exemption denied due to lack of beneficial ownership (Supreme Court decision). Read more |
Proposed legislation | Tax compliance | 06 March 2026 | Bill adopting Directive on Administrative Cooperation (DAC8) approved by lower house of Parliament. Read more |
Tax legislation approved and regulatory update | Various tax topics | 06 March 2026 | Expanded mandate of transfer pricing coordination group. Read more |
Proposed legislation | Income tax | 05 March 2026 | Consultation on changes to participation exemption and currency gains and losses on hedging instruments. Read more |
Norway
Norway | |||
Administrative and case law | Indirect tax | 19 March 2026 | Split Value Added Tax (VAT) treatment required for data center services provided to foreign customers with customer-owned servers (Tax Appeals Board decision). Read more |
Proposed legislation | Tax compliance | 17 March 2026 | Ministry of Finance accelerates mandatory digital bookkeeping and electronic invoicing (e-invoicing) requirements. Read more |
OECD
OECD | |||
Administrative and case law | Transfer Pricing | 04 March 2026 | Amount B pricing FAQs, updated Amount B pricing automation tool. Read more |
Poland
Poland | |||
KPMG publications | Various tax topics | 31 March 2026 | Legislation decreasing excise duty on fuel passed by lower house of Parliament, other tax developments. Read more |
KPMG publications | Various tax topics | 25 March 2026 | Revised bills amending Personal Income Tax and Corporate Income Tax Acts, other tax developments. Read more |
KPMG publications | Various tax topics | 19 March 2026 | DAC8 and DAC9 legislation signed by president, other tax developments. Read more |
KPMG publications | Various tax topics | 10 March 2026 | Summaries of recent Supreme Administrative Court decisions. Read more |
Tax legislation approved and regulatory update | Indirect tax | 10 March 2026 | General ruling on reduced excise duty rates for "mild hybrids". Read more |
KPMG publications | Various tax topics | 04 March 2026 | Application of Estonian CIT regime, taxation of gain from real estate as income from non-agricultural business activity. Read more |
Administrative and case law | Income tax | 03 March 2026 | Polish Anti-Tax Avoidance Council issues opinions on trademark amortization and closed-end investment funds. Read more |
Romania
Romania | |||
Proposed legislation | BEPS Pillar 2 | 18 March 2026 | Draft guidance clarifying accounting treatment of deferred tax under Pillar Two rules. Read more |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 10 March 2026 | Implementation of DAC9. Read more |
Tax legislation approved and regulatory update | Income tax | 03 March 2026 | New research and development (R&D) tax credit. Read more |
Slovakia
Slovakia | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 26 March 2026 | Overview of top-up tax obligations for large groups under Pillar Two. Read more |
Tax legislation approved and regulatory update | Income tax | 26 March 2026 | New withholding tax rules for software payments. Read more |
Slovenia
Slovenia | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 03 March 2026 | Pillar Two tax returns published. Read more |
South Africa
South Africa | |||
Tax legislation approved and regulatory update | Tax compliance | 23 March 2026 | Implementation of cryptoasset reporting framework (CARF). Read more |
Administrative and case law | Income tax | 06 March 2026 | Interest deductibility on loans used to redeem preference shares. Read more |
Administrative and case law | Tax compliance | 04 March 2026 | Business requirement specifications for FATCA, CRS, and CARF. Read more |
KPMG publications | Various tax topics | 02 March 2026 | Tax provisions in 2026/2027 budget. Read more |
Spain
Spain | |||
Tax legislation approved and regulatory update | Tax compliance | 26 March 2026 | Council of Ministers approves electronic invoicing (e-invoicing) mandate for business-to-business (B2B) transactions. Read more |
Administrative and case law | Indirect tax | 16 March 2026 | Activities of insurance comparison site qualify for Value Added Tax (VAT) exemption (National Court decision). Read more |
Administrative and case law | Income tax | 03 March 2026 | Spanish Supreme Court decision on beneficial ownership under the Interest and Royalties Directive and treaty override. Read more |
Administrative and case law | Income tax | 03 March 2026 | Dutch holding company did not meet beneficial ownership test under EU interest and Royalties Directive (IRD) (Supreme Court decision). Read more |
Sweden
Sweden | |||
Proposed legislation | Indirect tax | 18 March 2026 | Proposed amendments to Value Added Tax (VAT) rules. Read more |
United Kingdom
United Kingdom | |||
Administrative and case law | Tax compliance | 20 March 2026 | List of participating and reportable jurisdictions for cryptoasset reporting framework (CARF) published. Read more |
Administrative and case law | Income tax | 19 March 2026 | Amortization deductions denied under related-party rules, trading had not commenced for purposes of enterprise investment scheme (court decisions). Read more |
Administrative and case law | Transfer Pricing | 19 March 2026 | Transfer pricing and Diverted Profits Tax (DPT) statistics for financial year (FY) 2024-2025. Read more |
Administrative and case law | Various tax topics | 5 March 2026 | Deductibility of unamortized issue and discount costs, qualification as partnership for purposes of land transaction tax partnership relief rules. Read more |
