The United Nations’ efforts to establish a Framework Convention on International Tax Cooperation (UNFCITC) have entered a crucial phase. Over the past year, negotiations have evolved from discussions around broad principles to detailed deliberations on draft legal texts that could reshape international tax cooperation. Following four sessions between 2025 and early 2026, stakeholders convened on July 28, 2026, for a multi-stakeholder consultation that provided valuable insight into the priorities and concerns shaping the next phase of negotiations. These discussions gained added significance when the fifth session of the Intergovernmental Negotiating Committee (INC) met in New York from August 3, 2026, to August 13, 2026, to begin negotiating draft provisions of the proposed Convention and related protocols.[1]

Understanding the Journey So Far

The July consultation did not take place in isolation. It followed four substantive negotiating sessions during which Member States established the scope, objectives, and architecture of the proposed UN tax framework, guided by a resolution adopted by the UN for inclusive and effective international tax cooperation.[2] Discussions during these sessions focused on key issues such as tax cooperation, the taxation of cross-border services, dispute prevention and resolution, and the broader objective of creating a more inclusive system of global tax governance. By the end of the fourth session, negotiators had moved beyond conceptual discussions and laid out the groundwork for text-based negotiations, setting the stage for more detailed discussions.

Unlike many previous discussions on international tax reform, the UN process is increasingly focused on designing an institutional framework capable of evolving alongside future tax challenges. As explained during the July consultation, the emerging Framework Convention is intended to combine substantive commitments with implementation support, institutional arrangements, and mechanisms for future development. Rather than creating a static instrument, the draft seeks to establish a long-term framework supported by periodic reviews, adaptable governance structures, and implementation assistance, particularly for developing countries.[3]

What the July Consultation Revealed

The July 28, 2026, consultation brought together governments, businesses, academics, civil society organizations, and international institutions. While no formal decisions were taken, the consultation offered an important indication of stakeholder expectations and highlighted several themes that would later feature prominently in the August negotiations.

A recurring theme was the need for a more inclusive framework for international tax cooperation. Many participants emphasized that developing economies should have a stronger voice in shaping international tax rules and that future standards should reflect the realities faced by countries with varying levels of administrative capacity. The emphasis was not merely on representation, but on ensuring that international tax rules remain practical, implementable, and effective across a broad range of jurisdictions.

Stakeholders also focused on the challenges associated with taxing cross-border and digital services. As economic activity becomes increasingly detached from physical presence, governments are seeking clearer mechanisms to allocate taxing rights and ensure that income generated within their markets can be taxed appropriately. While much of the global debate in recent years has centered on automated digital services, such services may represent only a relatively small proportion of overall cross-border services. The proposed protocol is therefore intended to address a much broader category of service transactions.[4]

More significantly, the discussions indicated that negotiators are willing to move beyond traditional international tax concepts where necessary. The draft protocol contemplates new nexus rules designed specifically for remote services and, in certain circumstances, would allow taxpayers to elect to be taxed as if they had a physical presence in the source jurisdiction, with taxable income determined through a reasonable allocation of service revenue. This reflects a growing recognition that existing treaty concepts may not always be well suited to modern business models. In this regard, the proposed inclusion of Article 5 of the Framework Convention on the fair allocation of taxing rights which proposes that taxing rights are allocated based on where value is created, markets are located, revenues are generated, and users or data are located.[5] This Article is complemented by the first protocol to the Framework Convention on the Taxation of Income from Cross-Border Services, which provides for new nexus and source rules allocating taxing rights over fees for services, including rules that do not depend on physical presence, such as those based on the consumer or end user location.[6]

The consultation also underscored concerns about increasing tax disputes and the need for stronger mechanisms to prevent and resolve them. Businesses and tax administrations alike continue to grapple with the challenges posed by overlapping claims to tax income, divergent interpretations of treaty provisions, and the growing complexity of international tax rules. Importantly, the discussions suggest that the proposed dispute resolution protocol will extend beyond traditional mutual agreement procedures or arbitration frameworks. The draft is being developed as a menu of dispute prevention and resolution tools, including mechanisms such as advance pricing arrangements, joint audits, mediation, conciliation, and arbitration. It also contemplates coordinated procedures for disputes involving multiple jurisdictions, supported by common procedural rules and capacity-building assistance.[7]

From Consultation to Negotiation

The themes emerging from the July consultation were reflected in the fifth session of the INC held in August. For the first time, negotiators worked through draft legal texts covering the Framework Convention and protocols addressing the taxation of cross-border services and tax dispute prevention and resolution.[8]

While negotiations remain ongoing and final outcomes are yet to be determined, the August session marked an important milestone. The conversation has now shifted from identifying challenges to negotiating potential solutions. Questions relating to taxing rights, inclusivity, dispute resolution, and administrative practicality are no longer discussed solely at a conceptual level; they are increasingly being translated into proposed legal provisions.

For businesses and tax advisers, this development is particularly significant. The eventual framework could influence treaty policy, domestic legislation, and compliance obligations across a wide range of jurisdictions. The discussions around source-country taxation of services, alternative nexus rules, and multilateral dispute resolution mechanisms demonstrate that negotiators are prepared to consider approaches that extend beyond traditional treaty models where they believe existing rules no longer adequately address modern economic realities.

At the same time, stakeholders continue to emphasize the importance of balancing fairness with certainty. Governments seek greater protection of their tax bases and a more equitable allocation of taxing rights, while businesses continue to stress the need for predictability, simplicity, and administrability. How negotiators reconcile these objectives may ultimately determine both the effectiveness and the political viability of the final framework.

Conclusion

The July 28 multi-stakeholder consultation provided a valuable snapshot of the issues shaping one of the most significant international tax initiatives currently underway. It highlighted broad support for a more inclusive system of tax cooperation, a renewed focus on the taxation of cross-border services, and growing recognition of the need for stronger dispute prevention and resolution mechanisms.

The subsequent fifth session in August demonstrated that the UN process has entered a new phase, with negotiators now engaged in detailed discussions on draft legal provisions. Ultimately, the session aligned with the Committee’s goal of submitting the draft convention and two protocols to the General Assembly in 2027.[9] While considerable work remains before a final Convention is agreed, the direction of travel is becoming clearer. For tax professionals, the UN tax negotiations are no longer a distant policy discussion, they are an evolving process that could have a lasting impact on treaty policy, domestic tax legislation, and the future architecture of international taxation.

USA

July 2, 2026: IRS Introduces New TCC Registration Process for Certain Foreign Filers[10]

The IRS introduced a new Foreign Filer Transmitter Control Code (TCC) Registration System to facilitate the transition from the Filing Information Returns Electronically (FIRE) system to the Information Returns Intake System (IRIS) for the 2027 filing season. The new process enables eligible foreign entities whose authorized users do not hold a US Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN) to obtain the credentials required to access the International Data Exchange System (IDES) and electronically file Forms 1042-S, certain Forms 1099, and other information returns. Foreign filers with authorized users who hold an SSN or ITIN will continue to obtain a TCC through the standard IRIS application process.

July 2, 2026: Court Invalidates GILTI Rule Under Section 7805(a)[11]

The US Court of Federal Claims in Keysight Technologies Inc. v. United States, invalidated Treasury regulations aimed at addressing disparities between fiscal-year and calendar-year taxpayers in computing global intangible low-taxed income (GILTI). The court held that Treasury’s general authority under section 7805(a), without a more specific statutory delegation, did not authorize the regulations. The taxpayer argued that section 951A allowed section 197 amortization deductions in computing its GILTI inclusion and that the final regulations disallowing those deductions contradicted the statute and exceeded Treasury’s authority. Applying the post-Loper Bright framework, the court independently interpreted the statute and found Treasury’s interpretation unpersuasive.

July 15, 2026: Tax Court Invalidates Extraordinary Distribution Rules Limiting DRDs[12]

The US Tax Court, in Siemens Medical Solutions USA v. Commissioner, invalidated temporary Treasury regulations that limited the section 245A dividends received deduction for certain extraordinary distributions. The dispute arose after a controlled foreign corporation (CFC) completed related-party sales of foreign subsidiaries and later paid a dividend for which the taxpayer’s US consolidated group claimed a full section 245A deduction. The court held that Treasury could not use section 245A(g) or section 7805(a) to override unambiguous statutory text or impose a limitation Congress did not enact. Applying the post-Loper Bright framework and citing its prior decision in Varian Medical Systems, the court concluded that the effective-date mismatch among sections 245A, 965, and 951A did not permit Treasury to narrow the deduction by regulation.

July 31, 2026: Treasury Proposes CFC Year-End and PTEP Foreign Tax Credit Rules[13]

Treasury and the IRS released proposed regulations (REG-115145-25) addressing OBBBA provisions that repeal the one-month CFC deferral election and impose a 10% foreign tax credit haircut on certain distributions of section 951A previously taxed earnings and profits (PTEP). The proposed section 898 regulations would require many CFCs that previously used a November 30 year-end to align their taxable year with that of their majority US shareholder, potentially resulting in a one-month short taxable year for December 2025. The proposed rules address the allocation of foreign income taxes between the short taxable year and the succeeding taxable year, related elections, and reliance before final regulations are published. The proposed regulations also adopt rules for the new section 960(d)(4) haircut, including rules dividing section 951A PTEP groups into pre- and post-June 28, 2025, groups for purposes of applying the 10% haircut.

Canada

July 23, 2026: Canada Updates Tax Legislation and Implements 2025 Budget Measures[14]

Canada's Department of Finance released draft tax legislation proposing significant changes to the transfer pricing, hybrid mismatch, and taxable Canadian property regimes, along with amendments relating to LNG facilities and CCUS tax incentives. Key proposals include a simplified transfer pricing documentation regime for qualifying taxpayers, technical refinements to the hybrid mismatch rules, and an expanded scope of taxable Canadian property that may affect existing ownership structures. The measures remain subject to consultation and enactment.

Ireland

July 3, 2026: Irish High Court Denies Deduction for Foreign Royalty Withholding Tax[15]

The Irish High Court ruled that companies cannot claim a trading expense deduction for Foreign Royalty Withholding Tax (FWHT) once Ireland’s double tax relief regime applies, even if the taxpayer receives no practical benefit from foreign tax credits. The decision arose in the case of Avaya International Sales Limited, which argued that FWHT should be deductible because its Irish corporation tax liabilities were fully offset by R&D tax credits and other reliefs. The Court rejected that position, holding that Ireland’s foreign tax credit system is the exclusive mechanism for relieving double taxation. It further concluded that FWHT is a tax on income after it is earned, rather than an expense incurred in generating profits, making it ineligible for deduction. The ruling also distinguished FWHT from other deductible charges, such as irrecoverable Value Added Tax (VAT) and stamp duty, reinforcing Revenue’s position on the treatment of the foreign withholding taxes.

France

July 8, 2026: France Grants Additional Time for GloBE Information Return Submission Under Global Minimum Tax Framework[16]

France’s Ministry of Economy and Finance has postponed the filing deadline for the GloBE Information Return (GIR), together with the top-up tax return, from June 30, 2026, to September 1, 2026, for affected multinational groups. The decision was made after companies reported challenges during the first reporting cycle, including the complexity of compliance requirements, delays in software readiness, and technical issues associated with filing systems. The extension is intended to ease implementation pressures and support smoother compliance with the OECD’s Pillar Two global minimum tax rules.

July 10, 2026: France Publishes Practical Guide Ahead of Mandatory E-Invoicing Rollout[17]

France’s Ministry of Public Action and Public Accounts reaffirmed that the country’s electronic invoicing requirements will take effect as scheduled on September 1, 2026. To support businesses during the transition, the ministry indicated that tax authorities will adopt a pragmatic approach where taxpayers face implementation challenges in the initial stages. Alongside the announcement, the government released a practical guide designed to help businesses understand and comply with the new e-invoicing framework. The guide provides operational support for companies preparing their invoicing processes and systems for the reform. The initiative aims to facilitate a smoother transition as France advances its digital tax administration agenda.

July 27, 2026: France Delays Implementation of Recodified VAT Rules to 2027[18]

The French government has postponed the transfer of VAT provisions from the General Tax Code (CGI) to the Goods and Services Tax Code (CIBS), previously scheduled for September 1, 2026, to January 1, 2027, under Ordinance No. 2026-671. The delay is intended to avoid confusion, as the original timeline overlapped with the mandatory rollout of electronic invoicing requirements. While the implementation date has changed, the rules governing electronic invoicing remain unaffected. To ensure continuity, France has also extended the period during which references to existing CGI invoicing provisions may continue to be used, with the deadline now moved from December 31, 2027, to June 30, 2028.

Germany

July 3, 2026: Germany Revises Tax Treaty Negotiation Framework to Reflect OECD BEPS Standards and Domestic Tax Changes[19]

Germany’s Federal Ministry of Finance released an updated 2026 model convention for taxes on income and capital, replacing the previous 2013 version used as the basis for negotiating double taxation agreements. The revised framework incorporates key provisions from the 2017 OECD Model Tax Convention and outcomes of the OECD/G20 Base Erosion and Profit Shifting (BEPS) initiative, aiming to strengthen protections against tax avoidance and unfair tax practices. The update also aligns the negotiation framework with developments in German domestic tax legislation. While the document serves as a guide for future treaty discussions, Germany emphasized that it is not a mandatory template, allowing treaty terms to be tailored according to the economic relationship, legal systems, and tax policy objectives of the countries involved.

July 2, 2026: Germany Implements New Reforms to Tax Consultancy Framework and Key Tax Regulations[20]

Germany officially brought into effect a legislative package that updates the country's tax consultancy framework and introduces changes across several tax-related laws. The legislation was published in the Federal Law Gazette on July 2, 2026, and became effective from July 3, 2026. The reforms aim to modernize tax advisory services, streamline administrative procedures, and update tax provisions in areas such as real estate transfer tax and trade tax. The new measures also support greater flexibility in the delivery of tax assistance, while strengthening the legal framework governing tax professionals and related organizations.

July 9, 2026: Global Minimum Tax Reporting[21]

On July 9, 2026, the Bundestag approved Germany’s participation in the multilateral exchange of GloBE information, supporting the OECD’s 15% global minimum tax framework. Large multinational groups will generally be able to submit one centralized minimum-tax report instead of filing separately in every jurisdiction where they operate. Participating tax authorities will then exchange the relevant information automatically, reducing duplicate reporting and helping authorities identify possible under-taxation.

July 16, 2026: Tougher Action Against Tax and Financial Crime[22]

On July 16, 2026, the German government presented an enforcement plan focused on improving cooperation between federal customs investigators and state tax authorities. It proposes a joint tax and financial crime center, centralized data analysis, and AI-assisted identification of suspicious patterns. The plan also calls for stronger penalties, more effective recovery of illegally obtained assets, and the abolition of immunity through voluntary tax disclosures. Many measures will require further legislation and coordination with Germany’s states.

Italy

July 3, 2026: Italy Introduces Unified Income Tax Code as Part of Comprehensive Tax Reform Initiative[23]

Italy has officially adopted a new consolidated Income Tax Code that will take effect on January 1, 2027, representing a major step in the country's broader tax reform agenda. The legislation restructures and streamlines existing income tax rules that previously dispersed across the existing Income Tax Code (TUIR) and dozens of separate decrees and laws into a single framework comprising 377 articles, organized into four sections with nine annexes. The exercise is one of systematization, coordination, and updating rather than substantive reform: outdated, redundant, and inconsistent provisions are removed, but the underlying regimes are broadly preserved. The Code follows the consolidated act on VAT, while the consolidated act on compliance obligations and assessment is still being finalized. The measure was enacted through Legislative Decree No. 117, published in the Official Gazette No. 152 of July 3, 2026 (Ordinary Supplement No. 26/L), in force on July 4, 2026, and is intended to modernize the administration and interpretation of Italian income tax legislation.

July 21, 2026: Italy Sends "Omnibus" Corrective Decree to Parliament, Completing the Tax Reform Delegation[24]

The Italian Government transmitted to the Finance Committees of the Chamber of Deputies and the Senate the draft of the so-called ‘Omnibus’ corrective decree (Government Act No. 430), previously approved in preliminary examination by the Council of Ministers on June 10, 2026. Unlike the consolidated Income Tax Code, the measure is corrective and supplementary in nature, refining and coordinating provisions already enacted under the tax reform delegation of Law No. 111 of August 9, 2023. Following parliamentary opinions, the decree was definitively approved on August 4, 2026, and enacted as Legislative Decree No. 148 of August 7, 2026, published in Official Gazette No. 185 of August 11, 2026 (Ordinary Supplement No. 30), and in force since August 12, 2026. The final text expands the original scope from 28 to 37 articles across twelve titles, addressing employment and self-employment income (dependent family members, company car fringe benefits, purchased tax credits), business income (alignment of accounting and tax values, revision of the tax loss carry-forward and contribution regimes), international taxation (final foreign losses and the global minimum tax), VAT, inheritance and gift tax, excise duties, assessment and audits, financial income, the biennial advance tax agreement (concordato preventivo biennale), third sector entities, and tax penalties. Several provisions continue to amend the existing TUIR (Presidential Decree No. 917/1986) in parallel with the corresponding rules of the new Income Tax Code (Legislative Decree No. 117/2026), which applies from January 1, 2027, and they cross-refer to the new consolidated act on compliance obligations and assessment (Legislative Decree No. 141 of August 5, 2026).

July 29, 2026: Italy Issues Detailed CARF FAQs to Support Crypto Reporting Compliance[25]

The Italian Revenues Agency (Agenzia delle Entrate) have released comprehensive FAQs on the Crypto-Asset Reporting Framework (CARF), providing practical guidance on due diligence and reporting obligations introduced under DAC8 (Directive (EU) 2023/2226), transposed by Legislative Decree No. 194/2025, with reporting rules set by the Director's Provision of June 22, 2026), and aligned with the OECD’s international standard. The guidance clarifies key areas, including reporting scope, customer residency determination, and the treatment of crypto loans, collateral transfers, and lending-related transactions. It also addresses the reporting of high-value retail payment transactions and confirms the use of Digital Token Identifiers (DTIs), where available. Additionally, the FAQs explain that certain tokenized financial assets held through traditional custodians generally fall outside CARF’s scope. By closely reflecting OECD guidance, the FAQs aim to promote consistent implementation of crypto-asset reporting requirements and support compliance efforts by crypto-asset service providers operating within the EU.

Netherlands

July 1, 2026: Temporary Relief for FIIs From Tax Entity Classification Rules[26]

The Dutch State Secretary of Finance issued a decree granting temporary relief to fiscal investment institutions (FIIs) affected by the revised Dutch tax entity classification rules, which took effect on January 1, 2025. Under the relief, FIIs may continue to treat interests in investments that became tax transparent as a result of the revised rules as tax opaque for purposes of the FII distribution requirement and the financing limitation. The relief applies only to (shortly put) interest held directly before January 1, 2025, and remains available for a maximum of seven financial years (or the shorter actual holding period of the investment). To benefit from the relief, FIIs must file a written election request with the Dutch Tax Authority no later than September 22, 2026.

Please refer to A&M Tax Alert[27] for detailed analysis.

July 16, 2026: Ministry of Finance Updates ATAD2 Guidance[28]

The Dutch State Secretary of Finance published an updated decree on application of the Dutch anti-hybrid mismatch rules (ATAD2). While no major policy changes were introduced, the updated guidance provides clarifications on several areas that have generated practical uncertainty, including the interaction with the former US GILTI and current NCTI regimes, treatment of capitalized acquisition costs, disregarded/hybrid permanent establishments, and transfer pricing cost-plus structures. Notably, the decree includes additional examples aimed at preventing unintended double taxation outcomes and confirms that the Dutch hybrid mismatch rules should be interpreted in light of their underlying purpose, namely neutralizing hybrid mismatch arrangements without producing disproportionate results.

Please refer to A&M Tax Alert[29] for detailed analysis.

July 16, 2026: Public Consultation on Tax Technical Measures[30]

The Dutch government launched a public consultation on several technical tax measures intended to take effect on January 1, 2028. Key proposals include amending the Dutch tax treatment of reverse hybrid entities, under which the foreign substantial interest taxation regime would be expanded to cover interests in Dutch companies held through reverse hybrid entities resident outside the Netherlands. The bill also proposes simplifying procedural aspects of the corporate reorganization facilities, abolishing the innovation box production cost decision, introducing a real estate transfer tax reporting obligation for sellers of shares in a qualifying Dutch real estate company, and implementing several measures to simplify and improve the energy tax regime. Overall, the proposals primarily aim to clarify existing rules, improve tax administration, and address technical shortcomings in current legislation.

Please refer to A&M Tax Alert[31] for detailed analysis.

July 30, 2026: Position Paper on ‘Building Land’ Qualification[32]

The Dutch Tax Authority's Knowledge Group published a position paper confirming that land can qualify as ‘building land’ for Dutch VAT purposes (in Dutch: bouwterrein) even if the zoning plan does not yet permit construction at the time of supply. Referencing case law from the Court of Justice of the European Union and the Dutch Supreme Court, the Knowledge Group held that it suffices if sufficient objective indicators (such as a municipal vision document, correspondence with the municipality, or an urban development plan) demonstrate an intended future construction destination. In the case at hand, such indicators were present, so the land qualified as building land despite formal rezoning occurring years later.

Please refer to A&M Tax Alert[33] for detailed analysis.

July 30, 2026: Position Paper on FGR Definition and Carried/Co-Investment Vehicles[34]

One of the conditions for a Dutch or foreign limited partnership (LP) to qualify as a fund for joint account (FGR), which is treated as tax opaque for Dutch tax purposes, is (shortly put) that it constitutes an investment fund within the meaning of Article 1:1 of the Dutch Financial Supervision Act (FSA). In a position paper, the Knowledge Group of the Dutch Tax Authority clarifies how this requirement applies to co-investment and carried interest vehicles (i.e., LPs for investments by manager’s personnel). In this case, the LPs were Scottish Private Fund LPs that qualified as ‘feeder funds’ of a ‘master fund’ under the Alternative Investment Fund Managers Directive (AIFMD). The position paper confirms that the UK regulatory framework remains sufficiently comparable to the Dutch AIFMD-based regime for assessing whether an entity qualifies as an investment fund within the meaning of Article 1:1 FSA. Consequently, co-investment and carried LPs managed by a fund manager licensed by the Financial Conduct Authority can meet Article 1:1 FSA conditions.

Please refer to A&M Tax Alert[35] for detailed analysis.

July 23, 2026: Position Paper on the Exchange Principle and Investments[36]

The Dutch Tax Authority’s Knowledge Group issued a position paper confirming that the so-called exchange case law principle (in Dutch: ruilarresten) does not apply where investors exchange a directly held, managed securities portfolio for participations in an investment fund in the form of a fiscal investment institution (FII), as part of a manager led restructuring. According to the Knowledge Group, a directly held portfolio and participation in an FII are not assets of the same nature for purposes of the exchange doctrine. As a result, any gains realized on the transfer of the securities portfolio cannot be rolled over through application of the exchange case law.

Please refer to A&M Tax Alert[37] for detailed analysis.

Spain

July 21, 2026: New Tax Framework for SOCIMIs and Rentals[38]

The Spanish government published the draft Royal Decree-Law on Urgent Housing Measures to address the Housing Emergency, introducing a package of regulatory and tax measures aimed at increasing the availability of affordable housing. Among the most relevant tax provisions is the reform of the tax regime applicable to SOCIMIs (Spanish listed real estate investment companies). While SOCIMIs currently benefit from a 0% Corporate Income Tax (CIT) rate, the draft proposes the introduction of a special levy ranging from 15% to 25%, subject to potential reductions where a significant proportion of the residential portfolio is allocated to social or affordable housing. The draft also includes several measures affecting the rental market, notably the application of the standard 21% VAT rate to short-term tourist accommodation rentals. In addition, it proposes enhanced Personal Income Tax (PIT) incentives for landlords who offer affordable rents, reduce existing rental prices, or lease properties to young tenants, as well as tax benefits for eligible young renters. Approval of the draft by the Council of Ministers has been postponed until September 2026 to allow for further negotiations and to secure the parliamentary support required for its passage through Congress.

United Kingdom

July 13, 2026: UK Releases Draft Corporate Tax Measures Covering Pillar Two, Energy Levies, and Securities Transfers[39]

The UK tax authority, His Majesty's Revenue and Customs (HMRC), published draft legislation outlining several significant corporate tax measures for inclusion in Finance Bill 2026-27. Key proposals include implementing the OECD’s Pillar Two ‘side-by-side’ package, with related amendments generally applying to accounting periods beginning on or after January 1, 2026. The draft legislation also introduces a new Oil and Gas Revenue Levy, a permanent 35% charge on revenues exceeding specified oil and gas price thresholds, replacing the Energy Profits Levy by 2030, or earlier under certain conditions. Additional proposals would make the UK’s foreign permanent establishment exemption regime mandatory from 2027 and replace existing stamp duty and stamp duty reserve tax on securities with a new Securities Transfer Tax from 2027. The package also includes rules treating certain exploration and exploitation rights as immovable property to align treaty outcomes with policy intent.

July 22, 2026: UK GAAR Panel Rejects Inheritance Tax Planning Using Employee Benefit Trusts[40]

HMRC published two opinions from the General Anti-Abuse Rule (GAAR) Advisory Panel concluding that inheritance tax arrangements involving employee benefit trusts were unreasonable and therefore fall within the scope of the UK’s anti-avoidance rules. In both cases, the taxpayers sought to rely on Inheritance Tax (IHT) exemptions available for transfers of shares to employee trusts. However, the panel determined that the arrangements were designed primarily to preserve family access to assets while securing tax benefits, rather than achieving the intended policy objectives of the exemption. One case involved a family investment company, while the other concerned the restructuring and incorporation of a property business shortly before the taxpayer’s death.

July 1, 2026: UK Designates Additional Gilt-Edged Securities Exempt From Capital Gains Tax[41]

The UK Treasury issued the Taxation of Chargeable Gains (Gilt-Edged Securities) Order 2026 (SI 2026/725), designating 11 additional government securities as ‘gilt-edged securities’ for the purposes of the Taxation of Chargeable Gains Act 1992. As a result, gains arising on the disposal of these securities are exempt from capital gains tax (and corporation tax on chargeable gains), while any losses on disposal are not allowable for tax purposes. The Order came into force on June 30, 2026, and does not introduce any substantive policy changes, rather, it updates the list of qualifying securities eligible for the existing tax exemption.

July 1, 2026: HMRC Issues Notice 3 on UK Pillar Two Top-up Tax Return Filing Requirements[42]

HMRC has published Notice 3: Pillar Two Top-up Taxes Submission of Returns, setting out legally binding requirements for filing Multinational Top-up Tax (MTT) and Domestic Top-up Tax (DTT) returns in the UK. The notice provides guidance on return submission procedures, required information, amendments to filed returns, and notifications for groups that fall below the filing threshold. It also establishes the process for notifying HMRC when a group's GloBE Information Return has been filed in another jurisdiction that will exchange the relevant information with HMRC, thereby removing the need to file a separate UK information return. The notice has the force of law and forms part of the UK's Pillar Two administrative framework.

July 1, 2026: UK Supreme Court Clarifies LLP Salaried Member Rules[43]

The UK Supreme Court held in HMRC v BlueCrest Capital Management (UK) LLP that, for purposes of the LLP salaried member rules, a member’s ‘significant influence’ must arise from the LLP's governance and constitutional arrangements rather than solely from the individual's commercial or operational role. The Court upheld HMRC's position on the disguised salary test and remitted the significant influence issue to the First-tier Tribunal for reconsideration applying the correct legal test. The decision is expected to have important implications for LLPs assessing whether members fall within the employment tax regime.

July 15, 2026: UK Introduces Loan Charge Settlement Scheme Framework[44]

The UK has enacted the Employment and Trading Income etc. (Loan Charge Settlement Scheme) Regulations 2026 (SI 2026/821), establishing the new Loan Charge Settlement Scheme following the Government's response to the Independent Loan Charge Review. The regulations set out the eligibility criteria, the process for making and accepting settlement offers, the calculation of settlement amounts, payment arrangements, and the associated inheritance tax treatment for taxpayers seeking to settle liabilities arising from the loan charge regime. The regulations come into force on August 5, 2026, and provide a formal pathway for resolving outstanding income tax and National Insurance liabilities linked to disguised remuneration loan arrangements.

July 13, 2026: UK Commences Mandatory Registration Regime for Tax Advisers[45]

The UK has introduced regulations bringing into force the tax adviser registration framework under the Finance Act 2026. Under the new regime, tax advisers will be required to register with HMRC on a phased basis, with commencement dates varying by adviser category. As a transitional measure, advisers holding an Agent Services Account (ASA) immediately before August 18, 2026, will be treated as registered from that date. The regulations form part of HMRC's broader efforts to strengthen oversight of the tax advice market and improve compliance standards across the profession.

July 27, 2026: UK Supreme Court Clarifies Effect of GLO Test Case Judgments[46]

The UK Supreme Court held in AXA Insurance UK plc v. Commissioners of Inland Revenue that courts may depart from a Group Litigation Order (GLO) test case judgment when exceptional circumstances make it unjust to apply that decision to related claims. The Court also concluded that the earlier Prudential test case had not determined the relevant limitation issue for all claims within the GLO, allowing the appellants' claims to be assessed in light of subsequent legal developments. The judgment provides important guidance on the binding effect of GLO test cases and on the circumstances in which courts may revisit earlier determinations.

Hong Kong

July 27, 2026: Hong Kong Opens Consultation on Boosting CTC Tax Incentives[47]

The Financial Services and the Treasury Bureau and the Inland Revenue Department have opened a public consultation on proposed enhancements to the tax concession regime for corporate treasury centres (CTCs), taking forward the government's Action Plan 2026 to strengthen Hong Kong’s position as a regional treasury hub. A two-tier structure has been proposed. Under Tier One (an additional concession within the existing regime), the scope for interest deductions would be broadened, deferred deductions would be permitted for certain cross-border financing arrangements, and requirements relating to substantial activities and qualifying treasury transactions would be clarified — collectively enhancing tax certainty. Tier Two would create a pre-approval route under which qualifying CTCs and their associated companies could access additional benefits for five years, along with relief from the dedicated-CTC condition and the safe harbor rule, a 50% exemption for qualifying interest income of Hong Kong associated companies, and any interest paid to pre-approved non-Hong Kong associates shall be relieved from the subject-to-tax. The anti-tax-arbitrage rule would also be withdrawn for pre-approved Hong Kong associates under the proposed Tier Two path, subject to an interest deduction cap of 30% of EBITDA. The consultation runs from July 27, 2026, to September 4, 2026, with administrative clarifications expected later in 2026 and legislative amendments in the first half of 2027.

China

July 8, 2026: China Introduces More Flexible Tax Treatment for Corporate Mergers and Demergers[48]

China’s State Taxation Administration (STA) has introduced greater flexibility in the application of special tax treatment for qualifying corporate mergers and demergers under Announcement No. 13 of 2026. Previously, the parties to a reorganization were generally required to adopt consistent tax treatment, creating practical difficulties where the target had a diverse shareholder base. The new rules introduce a mixed-treatment approach: where consenting resident corporate shareholders collectively hold more than 50% of the merged or demerged enterprise, the portion attributable to those shareholders may qualify for tax-deferred special treatment, while the remaining portion is subject to general tax treatment. However, all resident corporate shareholders holding at least 5%, and all top ten resident corporate shareholders, must consent. These shareholders are also subject to a 12-month shareholding continuity requirement. For the portion subject to general tax treatment, the acquiring entity may elect a simplified method under which the difference between fair value and the original tax basis is amortized, for tax purposes, over ten years. The changes apply only to mergers and demergers with a reorganization date on or after January 1, 2026; the substantive requirements for special tax treatment under the existing rules remain unchanged.

July 24, 2026: China Introduces New Individual Income Tax Framework for Offshore Trusts[49]

China’s Ministry of Finance (MOF) and State Taxation Administration (STA) issued Announcement [2026] No. 21, together with STA Announcement [2026] No. 15, establishing China’s first comprehensive individual income tax framework specifically addressing offshore trusts. The new rules introduce a lifecycle-based regime covering the contribution of assets to an offshore trust, income arising during the trust’s operation, distributions and other economic benefits, and termination. For People’s Republic of China (PRC) resident individuals, contributing assets may be treated as a taxable disposal at market value, while income generated within the trust may be taxable annually even if it is not distributed. The framework also contains look-through rules addressing assets or income held through controlled offshore entities and certain arrangements involving non-residents and PRC resident beneficiaries. The rules create an immediate compliance priority for existing structures. Certain historical asset contributions and trust income are subject to a 90-day transitional filing and payment window from July 24, 2026, during which qualifying outstanding tax may be settled without late-payment surcharges. The accompanying administrative rules also introduce detailed annual reporting, documentation and trustee information requirements. Existing offshore trusts should therefore be reviewed promptly, including historical contributions, accumulated income and distributions, underlying entities, asset tax basis, control arrangements and the tax residence of relevant individuals. The interaction between the new PRC rules, foreign trust law, and applicable tax treaties may also require careful consideration.

India

July 16, 2026: Mumbai ITAT Clarifies Deductibility of Head Office and India-Specific Branch Expenses for Foreign Banks[50]

The Mumbai Income Tax Appellate Tribunal (ITAT), in the case of Standard Chartered Bank, held that expenditure incurred by a foreign bank's head office or overseas branches should not be disallowed merely because it was paid outside India. The Tribunal reiterated that the applicability of section 44C depends on the nature of the expenditure and distinguished general head office overheads from costs directly attributable to Indian branch operations. Expatriate salary costs and operational expenses with a demonstrable nexus to Indian business activities were held to be generally deductible, while the issue of full deduction of head office expenses under the India-UK tax treaty's non-discrimination article was remanded to the tax authorities for factual verification. The ruling reaffirmed that interest paid by an Indian branch to its head office does not constitute taxable income in India, being a payment to oneself.

Please refer to A&M Tax Alert[51] for detailed analysis.

July 17, 2026: Mauritius Cabinet Approves Ratification of India-Mauritius DTAA Protocol[52]

The Mauritius Cabinet approved the ratification of the 2024 Protocol to the India-Mauritius tax treaty (singed on March 7, 2004) after consultations with industry stakeholders and discussions with the Indian government. The Protocol aims to align the tax treaty with OECD BEPS minimum standards, by introducing a revised preamble to reiterate the common intention of both countries to eliminate double taxation, without creating opportunities for tax avoidance; and inclusion of a PPT rule under which the tax treaty benefits may be denied if one of the principal purposes of an arrangement or transaction was to obtain a tax benefit provided by the tax treaty.

The Protocol will enter into force following completion and notification of ratification procedures by both jurisdictions. While the Protocol has not yet entered into force, Mauritius' ratification marks a significant step toward implementation.

July 24, 2026: India Updates Crypto-Asset Reporting Guidance in Line with OECD Standards[53]

India's Ministry of Finance issued an updated Guidance Note on FATCA and CRS, providing further clarity on the reporting obligations of crypto exchanges and other intermediaries classified as reporting financial institutions under the Income Tax Act, 2025, and related rules. The revised guidance aligns domestic reporting requirements with the OECD framework and outlines key aspects, including the identification of reporting entities and reportable accounts, crypto-assets within scope, due diligence requirements, the treatment of trusts and partnerships, record-keeping obligations, and the filing process for Form 166. The updated Guidance Note was released on July 24, 2026.

July 30, 2026: Bengaluru ITAT Holds Buyback of Unexercised ESOPs Taxable as Capital Gains[54]

The Bengaluru ITAT in Pramod Kumar Jain v. DCIT held that consideration received on the repurchase of vested but unexercised ESOPs is taxable as capital gains, not as salary income. The Tribunal observed that taxation as a perquisite under section 17(2)(vi) arises only upon exercise of the option and the allotment or transfer of the underlying shares. Because the taxpayer's stock options were repurchased before exercise, the options represented a capital asset, and their extinguishment constituted a transfer taxable under the capital gains provisions. The ITAT further observed that the reporting of the amount as a perquisite and the withholding of tax under salary provisions do not conclusively determine the taxability or the character of the income. While the ruling provides valuable guidance on ESOP liquidity events and buyback arrangements commonly adopted by multinational entities, the matter is likely to be subject to further judicial scrutiny before higher courts.

Malaysia

July 7, 2026: Malaysia Introduces Special Voluntary Disclosure Programme for E-Invoicing Non-Compliance[55]

The Inland Revenue Board (IRB) introduced an e-Invoice Special Voluntary Disclosure Programme running from July 7, 2026, to December 31, 2027. Programme is available to taxpayers who adopted e-Invoicing within the prescribed timeline but failed to submit e-Invoices for certain transactions, submitted e-Invoices containing errors or non-compliant information, or have not submitted any e-Invoices since their mandatory implementation date. To participate, taxpayers must rectify their disclosures by submitting accurate e-Invoices in accordance with the applicable general and specific e-Invoicing guidelines. As a compliance incentive, the government will allow businesses to fully claim capital allowances within one year for expenditure incurred on acquiring information and communication technology (ICT) equipment, as well as on developing or modifying software for e-Invoicing purposes. The program was announced through a media release issued on July 7, 2026.

July 29, 2026: Malaysia Prolongs Foreign-Sourced Income Tax Exemption for Unit Trusts Until 2030[56]

Malaysia's Ministry of Finance has extended the income tax exemption available to qualifying unit trusts on foreign-sourced income received in Malaysia, with the exemption period now running until December 31, 2030, instead of December 31, 2026. The extension, previously announced under the 2026 Budget, was formalized through the Income Tax (Unit Trust in relation to Income Received in Malaysia from Outside Malaysia) (Exemption) 2024 (Amendment) Order 2026 [PU(A) 270/2026], which was gazetted on July 27, 2026. The amendment takes effect from January 1, 2027.

July 30, 2026: Malaysia Issues Transfer Pricing Guidelines on Controlled Financial Transactions: Intra-Group Loans[57]

The Inland Revenue Board of Malaysia issued the Malaysia Transfer Pricing Guidelines on Controlled Financial Transactions: Intra-Group Loans dated, July 30, 2026. The Guidelines supplement Chapter Nine of the Malaysia Transfer Pricing Guidelines 2024. Key developments include a stronger focus on debt-versus-equity classification, more detailed requirements for accurately delineating and pricing intra-group loans, and enhanced documentation expectations. Notably, the Guidelines introduce a simplified method allowing eligible taxpayers to use BNM’s Deposit Rate or Average Lending Rate (ALR) without a full benchmarking analysis, subject to conditions, including a RM50 million threshold.

July 22, 2026: Guideline on Capital Gains Tax Exemption on Share Disposal for Purposes of IPO[58]

The Income Tax (Initial Public Offering) (Exemption) Order 2024, which provides a Capital Gains Tax (CGT) exemption to companies, LLPs, trust bodies, and co-operative societies in respect of chargeable income from the disposal of unlisted shares of a Malaysian company in connection with the restructuring of any company for IPO purposes, has now been gazetted. The IRB has issued this Guideline to clarify the procedures for applying for the above CGT exemption, including an illustration of how to determine the one-year application window and the procedures for obtaining relief for successful applications.

Thailand

July 2, 2026: Thailand Revises Rules for Waiver or Reduction of Tax Penalties and Surcharges [59]

Thailand’s Revenue Department issued Revenue Department Order No. Tor. Por. 369/2569, revising the criteria for the waiver or reduction of penalties and surcharges relating to CIT, VAT, and specific business tax (SBT) under the Revenue Code. The order amends the existing framework under Tor. Por. 81/2542 and clarifies the conditions under which penalty relief may be granted where the taxpayer did not intend to evade tax and has cooperated with the tax authorities. A key amendment relates to the penalty reduction rules under section 89(1) of the Thai Revenue Code, which now separately address cases involving the revocation of a VAT registration and cases involving VAT non-registration, with certain differences in the applicable relief conditions and penalty reduction rates. While the amendments do not materially alter the existing relief framework, they provide clearer guidance on the applicable conditions and penalty reduction rates, enhancing certainty for taxpayers seeking penalty relief. Subsequently, the Revenue Department issued Revenue Department Order No. Tor. Por. 370/2569, which broadly delegates authority to Revenue Department officials to consider and process requests for the waiver or reduction of tax penalties and surcharges.

July 27, 2026: Thailand Extends Reduced 7% VAT Rate Through September 2027[60]

On July 27, 2026, the Thai Cabinet approved in principle a draft Royal Decree, to be issued under the Revenue Code, extending the reduced value‑added tax (VAT) rate of 7% for an additional year. The measure, effective from October 1, 2026 to September 30, 2027, applies to the sale of goods, the provision of services, and imports, and is intended to ease the cost‑of‑living burden on the public, stimulate domestic consumption, and maintain economic stability. Although the statutory VAT rate under Thai law is 10%, the government has consistently applied a reduced rate of 7% (technically 6.3% plus local tax) since 1997 as a temporary relief measure, that has, in practice, become effectively permanent. Businesses should continue applying the 7% VAT rate in their invoicing, accounting, and tax filings throughout the extended period.

Vietnam

July 1, 2026: Vietnam Introduces Key Changes To Tax Administration Regulations[61]

Vietnam issued Decree 252/2026/ND-CP (Decree 252) and Circular 89/2026/TT-BTC (Circular 89) on tax administration, effective July 1, 2026. Noticeably, Decree 252 and Circular 89 provides updates on several points, including:

The compliance and withholding framework for overseas corporate suppliers (e.g., generally, foreign suppliers conducting business activities through e-commerce/digital platforms with organizations and individuals in Vietnam, deriving revenue from Vietnam, and whose tax obligations have not been withheld, declared, and paid on their behalf by business organizations in Vietnam or by e-commerce platform operators, shall be responsible for directly registering, declaring, and paying taxes); more clarifications of the five-year limit for revising tax returns; more clarifications of classification of taxpayers for tax administration purposes; new capital transfer tax declaration form (including cases in which no income was generated); more clarifications of the requirements for overseas outward profit remittance requirements under the tax administration regulations (e.g., fully fulfilled financial obligations to Vietnamper regulated; submitted audited financial statements and the corporate income tax finalization return as regulated; fully paid all taxes, other state budget collections, late payment interest, and administrative penalties due as regulated; no outstanding tax liabilities; no accumulated loss).

In addition, the new Permanent Establishment (PE) rule is restated in the new circular on DTA, taking effect from July 1, 2026, (i.e., expanding the definition of a PE to specifically include e-commerce and digital platforms used by foreign companies to sell goods or services within Vietnam, even if those companies have no physical presence locally). The new DTA Circular also authorizes APA authority from the Ministry of Finance (MoF) to the Tax Department (consulted with MoF in some cases).

July 1, 2026: Vietnam Introduces Key Changes to Related-Party Transaction Regulations[62]

Vietnam has issued Decree 255/2026/ND-CP (Decree 255) on the tax administration of related-party transactions, effective July 1, 2026, and applicable from the 2026 corporate income tax period. Noticeably, Decree 255 provides updates on several points, inter alia expanding definition of related parties (e.g., additional criteria have been introduced to determine related-party relationships, such as borrowing or lending transactions amounting to at least 10% of owners’ contributed capital could, in certain circumstances, establish a related-party relationship); data source hierarchy (e.g., Decree 255 establishes the priority order of databases used for TP compliance and administration, such as giving priority to public and official data); country-by-country reporting (CbCR) compliance and requirements have been revised (e.g., the consolidated revenue threshold has been aligned with the international standard of EUR 750 million for the preceding tax year; the taxpayer in Vietnam designated by the Ultimate Parent Entity for CbCR filing shall prepare and submit the CbCR under Appendix IV of Decree 255 in xml format); the conditions for exemption from preparing TP documentation have been revised (e.g., the revenue threshold for exemption from transfer pricing documentation has been increased from VND 200 billion to VND 500 billion, subject to other conditions).

July 1, 2026: Vietnam Introduces Key Changes to Personal Income Tax Regulations[63]

Vietnam issued Decree 253/2026/ND-CP (Decree 253) and Circular 87/2026/TT-BTC (Circular 87) on personal income tax, effective July 1, 2026, except for regulations on business income and employment income of individual tax residents generally apply from the 2026 tax period. Notably, Decree 253 and Circular 87 provide a consistent PIT calculation approach for capital transfers by both individual tax resident and individual non-tax resident transferors (i.e., 20% on capital gain; if cost and related expenses cannot be determined: 2% on gross proceeds) and securities transfers by both individual tax resident and individual non-tax resident transferors (i.e., 0.1% on gross proceeds).

Japan

July 31, 2026:Application Procedures Commence for the Largest-Ever Tax Incentive for Large-Scale and High Value-Added Capital Investment[64]

Japan opened applications for its new tax incentive for large-scale and high value-added capital investment on July 31, 2026. The regime applies across all industries and provides either 100% immediate depreciation or a tax credit of up to 7% (4% for buildings, structures, and related facilities) for qualifying investments. Eligible assets include machinery, equipment, buildings, structures, software, tools, and fixtures, while used assets, leasing assets, R&D-only assets, and investment plans consisting solely of buildings are excluded. To qualify, taxpayers must obtain prior approval from the Ministry of Economy, Trade and Industry (METI), meet minimum investment thresholds of JPY 3.5 billion (JPY 500 million for SMEs), and demonstrate an expected average annual return on investment of at least 15%. The incentive applies to approved investment plans submitted by March 31, 2029, with eligible assets required to be acquired and placed in service within five years of approval. The regime is intended to stimulate large-scale domestic investment and productivity-enhancing capital expenditure, while imposing certain wage growth and domestic reinvestment conditions on large enterprises.

Oman

July 20, 2026: Oman Introduces Additional Conditions for Deductibility of Certain Business Expenses[65]

Oman has tightened the rules for deducting expenses arising from actions or decisions by government bodies and public authorities. Under the revised framework (Article 18 bis), such costs will be deductible only if they are incurred for the taxpayer's core business activities, are approved by the Oman Tax Authority, and are not connected to any breach of legal obligations. The change was introduced through Decision No. 180/2026 and will apply to tax years commencing on or after January 1, 2027.

Saudi Arabia

July 29, 2026: Saudi Arabia Adopts CRS MCAA Addendum[66]

Saudi Arabia signed the Addendum to the Competent Authority Agreement on the Automatic Exchange of Financial Account Information (CRS MCAA) on April 9, 2026, aligning with the OECD's enhanced Common Reporting Standard (CRS) framework. The Addendum incorporates additional information exchange requirements introduced through the 2023 CRS updates, supporting international tax challenges. According to the OECD's update released on July 29, 2026, the Addendum has been signed by 78 jurisdictions.

United Arab Emirates

July 15, 2026: UAE Clarifies Reporting Requirements for Downward Transfer Pricing Adjustments[67]

The UAE Federal Tax Authority (FTA) issued Public Clarification CTP011, providing guidance on downward transfer pricing adjustments made in corporate tax returns to align related-party transactions with the arm's length principle. The clarification confirms that taxpayers may make such adjustments without prior FTA approval, subject to full disclosure of the affected transactions, and the maintenance of adequate supporting documentation. It also outlines evidentiary requirements for taxpayers and clarifies that the guidance applies specifically to taxpayer-initiated downward adjustments reported in the tax return, rather than other transfer pricing adjustment mechanisms available under the corporate tax regime.

Please refer to A&M Tax Alert[68] for detailed analysis.

July 1, 2026: UAE Aligns Domestic Pillar Two Guidance With Latest OECD GloBE Interpretations[69]

The UAE issued Ministerial Decision No. 96 of 2026, updating the interpretative framework applicable to its Domestic Minimum Top-up Tax regime under Pillar Two. The revised guidance incorporates the OECD's latest Commentary and Administrative Guidance on the Global Anti-Base Erosion (GloBE) Rules, providing additional clarity on the operation of the regime for affected multinational enterprise groups. The decision replaces the earlier guidance in Ministerial Decision No. 88 of 2025 and applies to fiscal years commencing on or after January 1, 2025.

Please refer to A&M Tax Alert[70] for detailed analysis.

Australia

July 10, 2026: Australia Seeks Feedback on Proposed 30% Minimum Tax for Discretionary Trusts[71]

Australia's Treasury released a consultation paper on the design of a proposed 30% minimum tax on discretionary trusts, announced in the 2026-27 Federal Budget as part of broader efforts to enhance the equity and sustainability of the tax system. The measure is proposed to take effect from July 1, 2028. Under the proposal, trustees of discretionary trusts would be subject to a minimum 30% tax on the trust's taxable income. Beneficiaries would continue to include trust distributions in their assessable income, with eligible non-corporate beneficiaries able to claim non-refundable credits for tax paid by the trustee. Fixed trusts would remain outside the scope of the regime. To support the transition, the government has proposed expanded rollover relief for a three-year period beginning July 1, 2027, allowing trustees to move to alternative business or investment structures without immediate tax consequences. The consultation also seeks feedback on the design of the rollover relief, the treatment of excess franking credits, the scope of excluded entities and income, and the administration and collection of the minimum tax. Submissions closed on July 31, 2026.

• The UK introduced a new statutory notice under the Customs (Tariff Quotas) (EU Exit) Regulations 2020, establishing a framework for identifying ‘critical’ steel tariff quotas. Under the notice, a steel quota will be designated as critical once 90% of the quota volume for the relevant quota period has been allocated, enabling closer administration of quota utilization and import controls. The measure forms part of the UK's broader steel trade regime and took effect on July 1, 2026, alongside wider changes to the UK's steel safeguard measures.[72]

• On July 23, 2026, the United States announced additional section 301 tariffs on goods from 60 economies following investigations into their failure to impose and effectively enforce prohibitions on imports of goods produced with forced labour. The tariff rates are generally 10% or 12.5% and either cap the total tariff burden, including any applicable general duty, or apply in addition to the general duty. The tariffs apply broadly to goods from the affected economies, subject to specified product exemptions. The measure also provides for the establishment of tariff-rate quotas for certain textile and apparel products from Bangladesh, Cambodia, Indonesia, and Malaysia, under which specified volumes of such products may enter the United States free of section 301 tariffs, based on the respective economies’ imports of US textile goods and cotton.[73]

  Please refer to A&M Tax Alert[74] for detailed analysis.

• On July 24, 2026, a group of importers led by Learning Resources, Inc., filed suit in the Court of International Trade challenging USTR’s global section 301 tariffs. The complaint alleges that USTR exceeded its authority by imposing tariffs on imports from 60 economies without making the country-specific findings required by statute and assert claims under the Administrative Procedure Act (APA). The plaintiffs seek to vacate the tariff action, obtain refunds of duties paid, and enjoin further collection. A separate challenge by Burlap and Barrel, Inc. and Collective Horology LLC raises many of the same statutory, APA, and constitutional claims and additionally seeks class-wide relief on behalf of importers subject to the tariffs.[75]
• On July 20, 2026, President Trump signed three proclamations under section 338 of the Tariff Act of 1930 imposing additional 50% tariffs on specified Canadian imports in response to Canada's treatment of US motor vehicle, alcoholic beverage, and dairy exports. Although the proclamations are based on alleged discrimination in those three sectors, the tariffs apply to a broader range of covered Canadian products identified in the annexes to the proclamations. The tariffs apply regardless of whether the goods qualify for preferential treatment under the US-Mexico-Canada Agreement (USMCA) and generally exclude energy, potash, products subject to section 232 tariffs, fish, critical minerals, and certain other goods. The tariffs are scheduled to take effect 30 days after signing.[76]
• On July 22, 2026, USTR imposed an additional 25% tariff on all imports from Brazil, subject to specified exemptions, pursuant to a separate section 301 action. USTR found that a broad range of Brazilian acts, policies, and practices burden or restrict US commerce, including those relating to digital trade and electronic payment services; unfair, preferential tariffs; anti-corruption enforcement; intellectual property protection; ethanol market access; and illegal deforestation. Unlike the 60-economy section 301 action, the Brazil measure rests on country-specific findings unrelated to forced labor. However, Brazil is also included among the economies subject to the global forced-labor tariffs at a rate of 12.5%, potentially resulting in a combined tariff rate of 37.5% for certain imports.[77]

• The India-UK Comprehensive Economic and Trade Agreement (CETA) entered into force on July 15, 2026, roughly a year after the two countries signed it on 24 July 2025. The pact lowers tariff barriers and spans a wide range of sectors, including goods and services trade, digital commerce, investment, financial services, IP protection, telecommunications, and labor mobility, alongside government procurement and regulatory cooperation. Additional chapters cover innovation, SME support, sustainability, and transparency commitments.[78]

  Please refer to A&M Tax Alert[79] for detailed analysis.