- Algeria: The Finance Bill for 2026, presented to the National People's Assembly in October 2025, includes measures that will impact nonresidents doing business in Algeria. In particular, the “real profit” regime that applies to foreign companies that do not have a permanent establishment in Algeria will be eliminated so that such companies will be subject to withholding tax on their gross income. Additionally, foreign companies without a PE will be subject to the same compliance obligations as resident companies and profits generated in Algeria by branches of foreign companies will be deemed to be distributed even if they are not remitted to the head office. The bill is expected to be enacted before the end of 2025.
- Argentina: A resolution published on 21 October 2025 eliminates the requirement for taxpayers to disclose information on international transactions, retroactive as from 1 May.
- Australia: The government has announced changes to the proposed tax measures on high-balance superannuation accounts, including pushing forward the start date to 1 July 2026. The plan to tax unrealised capital gains on super balances above AUD 3 million has been scrapped; instead, additional tax will apply only to realised earnings. An additional tax of 15% will be applied on income attributable or apportioned to the share of the member’s balance that exceeds AUD 3 million (for an analysis of the changes, see the tax alert prepared by BDO in Australia).
- Bermuda: A law passed on 12 September 2025 introduces rules on beneficial ownership requiring legal entities to set up and maintain a beneficial ownership register. The register must include information about individuals who ultimately own or control the entity and the register must be updated within 14 days of any change. The data must be retained for five years after the ownership ends.
- Cambodia: As part of a tentative trade deal with the US, Cambodia has agreed not to introduce a digital services tax or similar type of tax.
- Canada: The tax authorities have revised their position on withholding tax requirements for expenses that are subcontractor fees for services provided in Canada (see the tax alert prepared by BDO in Canada).
- Chile: A resolution published on 26 August 2025 introduces a new reporting requirement for entities and large taxpayers on their tax sustainability measures starting from fiscal year 2026 (concerning reportable information from calendar year 2025).
- Colombia: A tax reform bill presented on 1 September 2025 contains several proposals that would affect tax rates on companies, including the following: (i) an increase in the rate for financial entities from 40% to 50%; (ii) an increase in the rate on dividends derived by nonresident companies and permanent establishments from 20% to 30%; and (iii) an increase in the rate from 3% to 5% for nonresident companies that meet the significant economic presence requirements and have opted to pay corporate income tax.
- Ecuador: A decree issued on 27 October 2025 clarifies new rules on the taxation of dividend/profit distributions by resident companies and permanent establishments. In particular, a 12% withholding tax is imposed on such distributions to residents and 10% when paid to nonresidents (increased to 12% if the beneficial owner is an Ecuador resident and 14% if the chain of ownership includes a resident in a tax haven or low tax jurisdiction and the beneficial owner is in Ecuador), with the distributing company acting as the withholding agent.
- Estonia: In a press release dated 18 September 2025, the government announced that agreement has been reached on the 2026 state budget and, as part of this agreement, the planned corporate income tax rate increase in 2026 (from 22% to 26%) is being abandoned in an effort to stimulate the economy. The rate will remain at 22%.
- European Union:
- The European Commission’s 2026 work programme released on 20 October 2025 includes the withdrawal of multiple legislative proposals, including the “unshell” directive, a new limit on the deduction of interest (DEBRA), a tax on certain financial transactions and a new EU transfer pricing platform.
- The Economic and Financial Affairs Council announced on 10 October 2025 that there are no changes to the EU list of noncooperative jurisdictions (currently 11 jurisdictions: American Samoa, Anguilla, Fiji, Guam, Palau, Panama, Russia, Samoa, Trinidad & Tobago, US Virgin Islands and Vanuatu). However, Vietnam was removed from the “grey list” and four jurisdictions were added (Greenland, Jordan, Morocco and Montenegro) following various commitments by the countries.
- Kazakhstan: An order published on 19 September 2025 and that will apply as from 1 January 2026 updates the list of countries with preferential tax regimes for purposes of Kazakhstan’s controlled foreign company rules. A country will be deemed to have a preferential tax regime if it has a corporate income tax rate of less than 10% or has laws on the confidentiality of financial information or confidentiality regarding the beneficial owners unless Kazakhstan has an exchange of information agreement in effect with the relevant country.
- Malaysia: As part of a tentative trade deal with the US, Malaysia has agreed not to impose a digital services tax (DST) or similar type of tax and to exempt US social media and cloud services providers from the requirement to contribute 6% of their revenue to a Malaysian fund. Malaysia currently levies a 6% DST as part of its GST regime on services provided by foreign companies.
- Mauritius: A Communique released by the tax authorities on 31 October 2025 sets out the compliance requirements for the new fair share contribution for companies as part of the Finance Act 2025 (for prior coverage, see the article in the August issue of Corporate Tax News).
- Netherlands: On 5 November 2025, the government proposed an amendment to the proposed measures in the 2026 tax plan to close a loophole in the lucrative interest rules (see article in this issue).
- Poland: Parliament has approved a gradual change in the corporate income tax rate on banks. The rate would increase from 19% to 30% on 1 January 2026, then drop to 26% in 2027 and 23% in 2028.
- Portugal: A law published on 7 November 2025 includes provisions that will gradually reduce the corporate income tax rate from 20% to 17% by 2028. The rate will drop to 19% in 2026 and 18% in 2027. A lower rate of 15% will apply to certain small and medium-sized companies.
- Singapore: The Inland Revenue Authority of Singapore has issued guidance on the classification of foreign entities for Singapore income tax purposes and included a list of foreign entities that are regarded as companies or partnerships for Singapore tax purposes.
- United Arab Emirates: The government has issued several sets of guidance:
- The Ministry of Finance issued a decision on 28 August 2025 that provides detailed rules on qualifying and excluded activities for corporate tax purposes in a free zone. The decision applies retroactively as from 1 June 2023.
- The Federal Tax Authority (FTA) issued a clarification on 28 August 2025 on the requirements for tax groups to prepare and maintain audited special purpose financial statements for corporate tax purposes.
- On 27 August 2025, the FTA released guidance on the need for corporate taxpayers to retain records and documentation to ensure accuracy of tax return information.
- Vietnam: A circular issued by the Ministry of Finance on 27 October 2925 contains guidance on the application of a new enterprise accounting regime in Vietnam that will apply with the initiative to align financial reporting in Vietnam with the adoption of IFRS starting 1 January 2026.
