International Tax Europe and Africa January 2026

      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 January and 31 January 2026.

      Rodney Lawrence

      Head of Consulting for Strategic Corporates, Tax & Legal

      KPMG International

      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.

      Austria
       

      Austria

      Tax legislation approved and regulatory update

      BEPS Pillar 2

      16 January 2026

      Amendments to local Pillar Two rules. Read more

      Back to top

      Belgium

       

      Belgium

      Other

      Various tax topics

      26 January 2026

      Updated 2026 Salary Criteria for Work and Single Permits. Read more

      Tax legislation approved and regulatory update

      Transfer Pricing

      08 January 2026

      Amended Local file form. Read more

      Back to top

      Bosnia and Herzegovina

       

      Bosnia and Herzegovina

      Tax legislation approved and regulatory update

      Indirect tax

      29 January 2026

      New excise duty rates on manufactured tobacco. Read more

      Tax legislation approved and regulatory update

      Indirect tax

      06 January 2026

      Instructions for Value Added Tax (VAT) refund procedures for nonresidents. Read more

      Back to top

      Bulgaria

       

      Bulgaria

      Tax legislation approved and regulatory update

      Indirect tax

      08 January 2026

      New Value Added Tax (VAT) regimes for supplies of goods by EU supplies, small enterprises. Read more

      Back to top

      Cameroon

       

      Cameroon

      Administrative and case law

      Income tax

      13 January 2026

      Guidance on mutual agreement procedures (MAPs). Read more

      Back to top

      Croatia

       

      Croatia

      Tax legislation approved and regulatory update

      Various tax topics

      29 January 2026

      Parliament approves amendments to Corporate Income Tax Act, General Tax Act. Read more

      Tax legislation approved and regulatory update

      Various tax topics

      29 January 2026

      Implementation of DAC8 and DAC9 requirements. Read more

      Treaties

      Income tax

      29 January 2026

      Tax treaty with Australia signed protocol to treaty with Switzerland ratified. Read more

      Treaties

      Income tax

      05 January 2026

      Income tax treaty signed. Read more

      Back to top

      Cyprus

       

      Cyprus

      Tax legislation approved and regulatory update

      Transfer Pricing

      26 January 2026

      Increased Local file thresholds for 2026. Read more

      Tax legislation approved and regulatory update

      BEPS Pillar 2

      16 January 2026

      Consent to Pillar Two Side-by-Side Package (SbS). Read more

      Tax legislation approved and regulatory update

      Various tax topics

      16 January 2026

      Repeal of stamp duty laws. Read more

      Other

      Various tax topics

      16 January 2026

      Programme of the Cyprus Council Presidency released. Read more

      Tax legislation approved and regulatory update

      Income tax

      16 January 2026

      Tax reform legislation enacted and effective January 1, 2026. Read more

      Administrative and case law

      Indirect tax

      07 January 2026

      Guidance on Value Added Tax (VAT) treatment of admissions to events. Read more

      Back to top

      Estonia
       

      Estonia

      Treaties

      Income tax

      16 January 2026

      Income tax treaties with Liechtenstein and Oman ratified. Read more

      Back to top

      Ethiopia

       

      Ethiopia

      Proposed legislation

      Various tax topics

      13 January 2026

      Proposed tax incentives for exports, startups, green energy projects. Read more

      Back to top

      European Union

       

      European Union

      Tax legislation approved and regulatory update

      Various tax topics

      16 January 2026

      Priorities of Cyprus European Union (EU) Council Presidency, state of play on implementation of DAC8 and DAC9. Read more

      Proposed legislation

      Various tax topics

      16 January 2026

      Commission launches public consultation on upcoming DAC recast proposal. Read more

      Tax legislation approved and regulatory update

      Tax compliance

      16 January 2026

      Navigating the first wave of European Union (EU) public country-by-country (CbyC) reporting. Read more

      Administrative and case law

      Indirect tax

      16 January 2026

      Transfer pricing adjustment only relevant for Value Added Tax (VAT) purposes if qualified as adjustment of transaction price agreed between parties. Read more

      Tax legislation approved and regulatory update

      Tax compliance

      16 January 2026

      Council of the European Union (EU): DAC8 implementation – state of play. Read more

      Tax legislation approved and regulatory update

      BEPS Pillar 2

      16 January 2026

      Council of the European Union (EU): DAC9 implementation – state of play. Read more

      Administrative and case law

      Income tax

      16 January 2026

      Court of Justice of the European Union (CJEU) referral on compatibility with European Union (EU) law of Germany’s double tax relief switch-over mechanism for foreign permanent establishments (PEs). Read more

      Administrative and case law

      Various tax topics

      16 January 2026

      Court of Justice of the European Union (CJEU) referral on Portugal’s regime imposing increased property tax rates on real estate held through tax haven structures. Read more

      Tax legislation approved and regulatory update

      Tax compliance

      14 January 2026

      Carbon border adjustment mechanism (CBAM) successfully entered into force on January 1, 2026. Read more

      Tax legislation approved and regulatory update

      BEPS Pillar 2

      13 January 2026

      European Commission (EC) notice confirming application of Pillar Two side-by-side package under European Union (EU) minimum tax directive. Read more

      Back to top

      France

       

      France

      Tax legislation approved and regulatory update

      BEPS Pillar 2

      29 January 2026

      User guide for GloBE information return (GIR). Read more

      Tax legislation approved and regulatory update

      Tax compliance

      29 January 2026

      Multiple reporting exemption regarding public country-by-country (CbC) transposed into law. Read more

      Tax legislation approved and regulatory update

      Indirect tax

      29 January 2026

      Value Added Tax (VAT) provisions recodified into Goods and Services Tax Code (CIBS). Read more

      Tax legislation approved and regulatory update

      Indirect tax

      13 January 2026

      Value Added Tax (VAT) exemption thresholds for goods, accommodations, and services reinstated retroactively to March 1, 2025. Read more

      Back to top

      Germany

       

      Germany

      Tax legislation approved and regulatory update

      BEPS Pillar 2

      29 January 2026

      Amendments to Pillar Two rules, DAC9, and DAC8 legislation enacted, other tax developments. Read more

      Treaties

      Income tax

      29 January 2026

      Protocols to tax treaties with Netherlands, Switzerland enter into force. Read more

      Tax legislation approved and regulatory update

      Tax compliance

      21 January 2026

      Activation of new “DIP” mass data interface for FATCA reporting. Read more

      Tax legislation approved and regulatory update

      Income tax

      16 January 2026

      Revised guidance on treaty interpretation. Read more

      Tax legislation approved and regulatory update

      BEPS Pillar 2

      16 January 2026

      Amendments to local Pillar Two rules. Read more

      Tax legislation approved and regulatory update

      Tax compliance

      13 January 2026

      Updated frequently asked question (FAQ) on mandatory electronic invoicing (e-invoicing). Read more

      KPMG publications

      Tax compliance

      05 January 2026

      Updated common reporting standard (CRS) guidance, implementation of DAC8 and cryptoasset reporting framework (CARF). Read more

      Back to top

      Ghana

       

      Ghana

      Tax legislation approved and regulatory update

      Income tax

      05 January 2026

      Modified taxation scheme (MTS) for “informal sector”. Read more

      Back to top

      Greece

       

      Greece

      Tax legislation approved and regulatory update

      Indirect tax

      28 January 2026

      Guidance on Value Added Tax (VAT) rate reduction for eligible islands. Read more

      Tax legislation approved and regulatory update

      Tax compliance

      15 January 2026

      Guidance on implementation of carbon border adjustment mechanism (CBAM). Read more

      Administrative and case law

      Income tax

      06 January 2026

      Guidance on timing of deductions during balancing market settlement process, tax incentive regime for corporate reorganizations. Read more

      Treaties

      Income tax

      06 January 2026

      Income tax treaty with UAE once again in force. Read more

      Tax legislation approved and regulatory update

      Income tax

      06 January 2026

      List of countries with preferential tax regimes for FY2023, list of non-cooperative countries for FY2024. Read more

      Tax legislation approved and regulatory update

      Income tax

      05 January 2026

      Guidance on taxation of distribution or capitalization of untaxed profits from prior years. Read more

      Back to top

      Guernsey

       

      Guernsey

      Tax legislation approved and regulatory update

      Tax compliance

      28 January 2026

      Updated guidance on implementation of Common Reporting Standard (CRS 2.0) (Guernsey). Read more

      Back to top

      Hungary

       

      Hungary

      Treaties

      Income tax

      13 January 2026

      Entry into force of amending protocol to Switzerland income tax treaty. Read more

      Back to top

      Isle of Man

       

      Isle of Man

      Tax legislation approved and regulatory update

      Tax compliance

      27 January 2026

      Industry Advisory Notice on cryptoasset reporting framework (CARF). Read more

      Back to top

      Italy

       

      Italy

      Tax legislation approved and regulatory update

      Various tax topics

      27 January 2026

      Tax measures in 2026 Budget Law. Read more

      Tax legislation approved and regulatory update

      Various tax topics

      16 January 2026

      2026 Budget Bill introduces changes to financial transaction tax (FTT) and other tax measures. Read more

      Back to top

      Jersey

       

      Jersey

      Tax legislation approved and regulatory update

      BEPS Pillar 2

      16 January 2026

      Extension of the Multinational Corporate Income Tax (MCIT) registration deadline. Read more

      Back to top

      Kenya

       

      Kenya

      Administrative and case law

      Indirect tax

      20 January 2026

      KPMG report: Digital platform operator with transactional control liable for valued added tax (VAT) (Kenya High Court decision). Read more

      Tax legislation approved and regulatory update

      Tax compliance

      07 January 2026

      Tax return information to be validated against specified data sources. Read more

      Tax legislation approved and regulatory update

      Tax compliance

      07 January 2026

      New standards levy on manufacturing turnover. Read more

      Administrative and case law

      Indirect tax

      07 January 2026

      Digital platform operator with transactional control liable for Value Added Tax (VAT) (High Court decision). Read more

      Back to top

      Latvia

       

      Latvia

      Tax legislation approved and regulatory update

      Transfer Pricing

      30 January 2026

      New requirements for controlled transactions report. Read more

      KPMG publications

      Various tax topics

      20 January 2026

      Tax card for 2026. Read more

      Treaties

      Income tax

      07 January 2026

      Income tax treaties with Latvia and Montenegro approved by Parliament. Read more

      Back to top

      Liberia

       

      Liberia

      Proposed legislation

      Various tax topics

      16 January 2026

      Draft 2026 budget includes measures to tax digital economy, increase in goods and services tax (GST). Read more

      Back to top

      Liechtenstein

       

      Liechtenstein

      Tax legislation approved and regulatory update

      Tax compliance

      08 January 2026

      Cryptoasset reporting framework (CARF) regulation enacted. Read more

      Back to top

      Luxembourg

       

      Luxembourg

      Tax legislation approved and regulatory update

      Income tax

      22 January 2026

      Start-up investment tax credit enacted. Read more

      Proposed legislation

      BEPS Pillar 2

      16 January 2026

      Amendments to local Pillar Two rules. Read more

      Tax legislation approved and regulatory update

      BEPS Pillar 2

      16 January 2026

      Pillar Two registration and reporting forms. Read more

      Treaties

      Income tax

      07 January 2026

      Amending protocols to income tax treaties with Georgia and San Marino approved, tax treaty with Montenegro effective October 1, 2025. Read more

      Back to top

      Moldova

       

      Moldova

      Administrative and case law

      Income tax

      07 January 2026

      Guidance on application of small and medium enterprises (SME) tax regime. Read more

      Administrative and case law

      Indirect tax

      07 January 2026

      Guidance on application of Value Added Tax (VAT) to sales conducted abroad, commissions charged by freelance services platforms, electricity and gas supplies. Read more

      Tax legislation approved and regulatory update

      Tax compliance

      07 January 2026

      Amended list of automatic exchange of information (AEOI) participating and reportable jurisdictions. Read more

      Back to top

      Monaco

       

      Monaco

      Treaties

      Tax compliance

      16 January 2026

      Protocol amending automatic exchange of financial account information (AEOI) agreement with European Union (EU) effective January 1, 2026. Read more

      Back to top

      Mozambique

       

      Mozambique

      KPMG publications

      Various tax topics

      07 January 2026

      Amendments to Value Added Tax, corporate and individual income tax, excise tax, and customs laws. Read more

      Back to top

      Namibia

       

      Namibia

      Proposed legislation

      Various tax topics

      06 January 2026

      Tax proposals in 2025/2026 mid-year budget review. Read more

      Back to top

      Netherlands

       

      Netherlands

      Administrative and case law

      Income tax

      22 January 2026

      Interest on loan from Belgium coordination center is non-deductible (Supreme Court decision). Read more

      Tax legislation approved and regulatory update

      BEPS Pillar 2

      16 January 2026

      Amendments to local Pillar Two rules. Read more

      Administrative and case law

      Income tax

      16 January 2026

      Dutch Supreme Court confirms ‘fraus legis’ for deduction of interest from debt related to the purchase of a participation. Read more

      Tax legislation approved and regulatory update

      Income tax

      14 January 2026

      Foreign tax credits to alleviate double taxation of assets from trusts. Read more

      Back to top

      Niger

       

      Niger

      Tax legislation approved and regulatory update

      Various tax topics

      16 January 2026

      Expanded solidarity fund contribution introduces various levies and tax incentives. Read more

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      Nigeria

       

      Nigeria

      Administrative and case law

      Indirect tax

      29 January 2026

      Share-purchase agreements are subject to stamp duties. Read more

      Tax legislation approved and regulatory update

      Indirect tax

      16 January 2026

      New 15% import duty on fuel, other recent tax-related developments. Read more

      Tax legislation approved and regulatory update

      Various tax topics

      06 January 2026

      “Certified” versions of tax reform legislation released by National Assembly. Read more

      Back to top

      North Macedonia

       

      North Macedonia

      Tax legislation approved and regulatory update

      Various tax topics

      08 January 2026

      Value Added Tax (VAT) law amendments, new guidance on Pillar Two top-up tax. Read more

      Back to top

      Norway

       

      Norway

      Tax legislation approved and regulatory update

      BEPS Pillar 2

      16 January 2026

      Amendments to local Pillar Two rules. Read more

      Back to top

      OECD

       

      OECD

      Other

      Transfer Pricing

      22 January 2026

      Fourth batch of updated transfer pricing country profiles. Read more

      Treaties

      BEPS Pillar 2

      16 January 2026

      List of signatories of the GloBE Information Return Multilateral Competent Authority Agreement (GIR MCAA) updated (Pillar Two). Read more

      Other

      BEPS Pillar 2

      16 January 2026

      Updated Central Record for Pillar Two purposes. Read more

      Other

      Various tax topics

      14 January 2026

      KPMG report: 2025 update to Organisation for Economic Co-operation and Development (OECD) Model Tax Convention. Read more

      KPMG publications

      Indirect tax

      14 January 2026

      Guidance on digital continuous transactional reporting (DCTR) for Value Added Tax (VAT). Read more

      Other

      BEPS Pillar 2

      05 January 2026

      Agreement reached on Pillar Two side-by-side package. Read more

      Back to top

      Poland

       

      Poland

      Proposed legislation

      Indirect tax

      30 January 2026

      Proposed digital services tax. Read more

      KPMG publications

      Various tax topics

      22 January 2026

      Amendments to transfer pricing regulations, other tax developments. Read more

      Back to top

      Portugal

       

      Portugal

      Tax legislation approved and regulatory update

      BEPS Pillar 2

      16 January 2026

      Extension of Pillar Two registration deadline. Read more

      Back to top

      Romania

       

      Romania

      Proposed legislation

      BEPS Pillar 2

      16 January 2026

      Public consultation on guidance for global anti-base erosion (GloBE) information return (GIR). Read more

      Tax legislation approved and regulatory update

      Various tax topics

      13 January 2026

      Amendments to various direct and indirect taxes, new electronic invoicing obligations. Read more

      Back to top

      Serbia

       

      Serbia

      Tax legislation approved and regulatory update

      Indirect tax

      29 January 2026

      Value Added Tax (VAT) refund for 2025 to foreign taxpayers. Read more

      Back to top

      Slovakia

       

      Slovakia

      Proposed legislation

      Indirect tax

      26 January 2026

      Draft amendment to Value Added Tax (VAT) law. Read more

      Back to top

      Slovenia

       

      Slovenia

      Tax legislation approved and regulatory update

      Various tax topics

      14 January 2026

      Changes to taxation of derivative financial instruments and corporate income tax. Read more

      Back to top

      Spain

       

      Spain

      Tax legislation approved and regulatory update

      Various tax topics

      20 January 2026

      New direct and indirect tax measures for 2025 and 2026. Read more

      Tax legislation approved and regulatory update

      Tax compliance

      15 January 2026

      Value Added Tax (VAT) related compliance for January and February 2026. Read more

      Administrative and case law

      Tax compliance

      06 January 2026

      Updated guidance on common errors in common reporting standard (CRS) reports received via Form 289. Read more

      Back to top

      Sweden

       

      Sweden

      Proposed legislation

      BEPS Pillar 2

      29 January 2026

      Further amendments to Pillar Two legislation. Read more

      Proposed legislation

      Indirect tax

      29 January 2026

      New Value Added Tax (VAT) deduction rules proposed for mixed activities. Read more

      Proposed legislation

      Indirect tax

      29 January 2026

      Proposed tax increase on certain tobacco products. Read more

      Proposed legislation

      Income tax

      29 January 2026

      Proposed dividend withholding tax exemption for foreign states. Read more

      Proposed legislation

      Tax compliance

      16 January 2026

      Draft legislation implementing DAC9. Read more

      Proposed legislation

      Income tax

      16 January 2026

      Proposed enhancements to tonnage taxation system. Read more

      Back to top

      Tunisia

       

      Tunisia

      Tax legislation approved and regulatory update

      Indirect tax

      15 January 2026

      Expanded electronic invoicing (e-invoicing) mandate to cover services, in addition to goods. Read more

      Back to top

      United Kingdom

       

      United Kingdom

      Tax legislation approved and regulatory update

      Various tax topics

      22 January 2026

      Tax measures in Scottish budget 2026-2027. Read more

      Tax legislation approved and regulatory update

      Transfer Pricing

      22 January 2026

      Updated transfer pricing guidelines for compliance. Read more

      Proposed legislation

      Various tax topics

      08 January 2026

      Draft guidance on new advance tax certainty service (ATCS). Read more

      Administrative and case law

      Income tax

      08 January 2026

      Providing scientific education through digital platform does not qualify for research and development (R&D) tax relief (First-tier Tribunal decision). Read more

      Administrative and case law

      Indirect tax

      08 January 2026

      Stamp duty land tax general anti-avoidance rule applied to series of intra-group transactions (Court of Appeal decision). Read more

      Back to top

      Zimbabwe

       

      Zimbabwe

      Tax legislation approved and regulatory update

      Indirect tax

      22 January 2026

      Digital services withholding in lieu of nonresident Value Added Tax collection. Read more

      Back to top

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