Nomadic Tax Institute

Policy updates

Publicly sourced cross-border tax developments. Dates, status and scope are shown separately so they can be read in context.

2645 updates

Scope: EU / EEA

Cyprus

Status requires verification

Pillar 2 Global Minimum Tax Directive: Cyprus FAQ confirms qualified status of its Income Inclusion Rule

The European Commission published a Frequently Asked Question clarifying that Cyprus’s domestically implemented Income Inclusion Rule (IIR) must be treated by all EU Member States as *qualified* under the Pillar Two Directive for fiscal years commencing on or after 31 December 2023, ensuring that its tax rules are recognised for purposes of EU-wide compliance and avoiding dual filings. It obliges Cyprus to receive Top-up Tax Information Returns by 31 May 2026 and requires exchange under DAC9 by other Member States in time for the first exchange deadline.

Editorial impact label: High

Published
Not recorded
Policy event
Not recorded
Effective
Dec 31, 2023
Verification
Not recorded

Open cited source

Scope: Africa

Status requires verification

Implementation of Advance Pricing Agreements (APAs)

SARS has initiated a formal APA programme to provide binding agreements on transfer pricing for cross-border related-party transactions. Notices prescribing eligibility, application fees, required documentation, and procedural guidelines (Notices 7790-7792, 7787-7789) were issued on 7 August 2026, following the APA legislation that took effect on 22 December 2023. Implications: businesses can gain certainty, reduce audit risk, but must meet strict documentation and compliance obligations.

Editorial impact label: High

Published
Not recorded
Policy event
Not recorded
Effective
Dec 22, 2023
Verification
Not recorded

Open cited source

Scope: Australia

Status requires verification

New thin capitalisation rules and debt deduction creation rules (DDCR) for private groups

Australia has aligned its interest limitation and thin capitalisation rules with OECD BEPS Action 4. For income years starting on or after **1 July 2023**, entities (including privately-owned and overseas-controlled groups) are subject to the new thin capitalisation tests: fixed ratio test (30% of EBITDA), group ratio test, or third-party debt test. The DDCR apply from **1 July 2024**, denying deductions arising from related-party loans used for asset acquisitions, distributions or returns of capital. There is a de minimis exemption of AUD 2 million where total associate-inclusive debt deductions do not exceed that threshold.

Editorial impact label: High

Published
Not recorded
Policy event
Not recorded
Effective
Jul 1, 2023
Verification
Not recorded

Open cited source

Scope: United Kingdom

Status requires verification

Government announces simplified tax reporting for self-employed and small businesses

The UK government announced reforms to the tax system that will make it easier for small businesses to fill out their returns. The changes, effective from 2023, will mean businesses will be taxed on profits arising in a tax year, rather than profits of accounts ending in the tax year. This aligns the taxation of self-employed profits with other forms of income, such as property and investment income, and aims to reduce errors and simplify tax reporting.

Editorial impact label: Medium

Published
Not recorded
Policy event
Not recorded
Effective
Apr 6, 2023
Verification
Not recorded

Open cited source

Scope: Canada

Proposed

Employee Ownership Trust Tax Exemption made permanent (Spring Economic Update 2026 proposal)

From the Spring Economic Update 2026: legislative proposals to make permanent an exemption for up to $10 million in capital gains when an individual sells a business to an Employee Ownership Trust or worker co-op. Previously temporary. This has implications for business succession planning and wealth transfer.

Editorial impact label: High

Published
Not recorded
Policy event
Not recorded
Effective
Jan 1, 2023
Verification
Not recorded

Open cited source