Indirect Tax
Dominican Republic mandates e-invoicing from 1 November 2026
(Excerpts from various sources)
The Dominican Republic’s General Directorate of Internal Revenue has mandated large local taxpayers and medium-sized taxpayers to issue invoices exclusively using Type ‘E’ electronic fiscal voucher (e-CFs) sequences w.e.f. 1 November 2026. The existing Type ‘B’ non-electronic fiscal vouchers will remain valid only up to 31 October 2026 and may thereafter be used solely in officially declared contingency situations.
On the other hand, small, micro and unclassified taxpayers are required to transition to the e-invoicing regime by 15 November 2026.
Non-compliance with the mandatory e-invoicing requirements may attract penalties under Law No. 32-23 on Electronic Invoicing.
Malaysia increases threshold for mandatory e-invoicing to RM3 million
(Excerpts from various sources)
Malaysia has increased the mandatory e-invoicing threshold from RM1 million to RM3 million, effective 1 September 2026. Resultantly, businesses with annual revenue or sales below RM3 million, including many MSMEs, are no longer required to implement e-invoicing.
The revised threshold is expected to benefit over 1.1 million businesses by lowering compliance costs, implementation efforts and administrative requirements.
The measure allows eligible businesses to continue issuing invoices in non-electronic format, thus supporting a smoother and more gradual transition to Malaysia's e-invoicing regime.
Sale of Cryptocurrencies and Stablecoins outside VAT ambit, rules Taiwan’s MoF
(Excerpts from various sources)
Taiwan’s Ministry of Finance (MoF) has ruled that sales of virtual assets that are used for payment or investment purposes, including cryptocurrencies and stablecoins, would not be subject to business tax (VAT), under the Virtual Asset Service Act.
On the other hand, service fees and commissions collected by virtual asset service providers for exchange and related services would be subjected to VAT.
NFTs are excluded from the definition of ‘virtual assets’ under the Virtual Asset Service Act and therefore, their sale and use in exchanges for goods or services would continue to be subject to business tax under existing rules.
Chile introduces annual filing for Domestic Digital Content platforms
(Excerpts from vatupdate.com)
Chilean Tax Administration, viz. Internal Revenue Service (SII) has introduced a new annual reporting obligation for domestic digital platforms acting as intermediaries between users / subscribers and digital content creators and content-providing companies.
Such platforms must file Sworn Statement Form No. 1965 disclosing the income, remuneration and other monetary consideration received or accrued by domestic digital content creators and content-providing companies.
Beginning in tax year 2027 covering income earned during 2026, the statement must be filed by 29 March every year. The measure aims to enhance tax transparency, with penalties applicable for non-filing, delayed filing or inaccurate reporting.
Uzbekistan expands tax rules for digital services and e-commerce
(Excerpts from various sources)
Uzbekistan has enacted Law No. ZRU-1173 expanding the tax obligations for non-resident providers of electronic services and e-commerce operators.
Accordingly, goods sold through electronic trading platforms will be deemed to have been supplied in Uzbekistan where both the purchaser and delivery location are in Uzbekistan. Resultantly, non-resident businesses must submit registration or deregistration applications within 30 days of commencing or terminating the relevant activity and must file tax reports electronically.
The law also introduces additional compliance obligations for digital platforms, order aggregators and streaming service providers, while designating certain intermediaries as tax agents.
Belgium aligns VAT rules on temporary EU goods movement with ViDA implementation in July 2028
(Excerpts from vatcalc.com)
Belgium has retained the broader VAT “non-transfer” treatment for temporary movement of own goods between Belgium and EU Member States for use in providing services until 30 July 2028, aligning the change with ViDA’s Single VAT Registration Reforms.
Transfer Pricing
Netherlands Proposes New Pillar Two Safe Harbours under 2027 Tax Plan
The Netherlands has proposed significant amendments to its domestic Pillar Two legislation as part of the 2027 Tax Plan, aligning its rules with the OECD Inclusive Framework's January 2026 Side-by-Side Package.
The proposed measures introduce four new Pillar Two safe harbors, extend the Transitional Country-by-Country Reporting (CbCR) Safe Harbour, and amend the treatment of certain 52- and 53-week accounting periods.
Notably, several of these provisions are intended to apply retrospectively to fiscal years beginning in late 2025 or 2026, demonstrating the Dutch government's commitment to facilitating Pillar Two implementation while reducing compliance burdens for multinational enterprise (MNE) groups.
A key aspect of the proposal is the introduction of a permanent Simplified Effective Tax Rate (ETR) Safe Harbor, under which no top-up tax would arise in a tested jurisdiction where the simplified ETR equals or exceeds 15%, or where the jurisdiction incurs a simplified loss. The framework also provides specific rules for permanent establishments, joint ventures, and joint venture subsidiaries, offering streamlined compliance for complex multinational group structures.
The proposed legislation further introduces detailed rules relating to income and tax adjustments, deferred taxes, transfer pricing adjustments, asset transfers, cross-border allocations, and other special entity scenarios. To ensure the integrity of the regime, taxpayers applying the safe harbor would be expected to adhere to key principles such as matching income and taxes, full allocation, and the avoidance of duplicate recognition of expenses, losses, or taxes, thereby promoting consistent and reliable application of the simplified Pillar Two rules.
Another important aspect of the proposal is the extension of the Transitional CbCR Safe Harbour, providing continued administrative relief for qualifying groups during the transition to the full Pillar Two regime. While the OECD framework generally contemplates the new safe harbors applying to fiscal years beginning on or after 31 December 2026, the Netherlands intends to permit early adoption from fiscal years beginning on or after 31 December 2025. Certain provisions implementing the OECD Side-by-Side Package are also proposed to apply retroactively to reporting years commencing on or after 1 January 2026.
Our comments
The proposed amendments represent a significant step in the Netherlands' ongoing implementation of Pillar Two and are expected to provide meaningful compliance simplifications and greater certainty for in-scope MNE groups.
Businesses with Dutch operations should assess their eligibility for the new safe harbors, evaluate the impact on their Pillar Two calculations and reporting obligations, and closely monitor the legislative process leading up to the expected enactment of the 2027 Tax Plan.
UAE Issues Pillar Two Guidance on Scope and Registration Requirements
The UAE Federal Tax Authority (FTA) has issued comprehensive guidance on the scope and registration requirements under the UAE’s Qualified Domestic Minimum Top-up Tax (QDMTT) regime, providing much-needed clarity for multinational enterprise (MNE) groups that may be subject to the OECD Pillar Two rules. The guidance focuses on determining whether a group falls within the scope of the UAE minimum tax legislation and outlines the registration obligations for affected entities.
A key aspect of the guidance is the clarification of the conditions under which a group will be considered in scope of the UAE QDMTT regime. The guidance explains the application of the consolidation and deemed consolidation tests, the consolidated revenue threshold requirement, and the treatment of sovereign wealth fund structures. These explanations are accompanied by practical examples to assist taxpayers in assessing whether the Pillar Two rules apply to their group structure.
The guidance also provides detailed clarification on the different categories of entities that may be subject to the QDMTT rules. This includes explanations of fundamental Pillar Two concepts such as constituent entities, permanent establishments (PEs), minority-owned constituent entities, joint ventures and their subsidiaries, flow-through entities, and hybrid entities. These clarifications are intended to help businesses correctly identify the entities that must be included within their Pillar Two compliance framework.
In addition, the guidance sets out the registration requirements and procedures applicable to different types of entities within the scope of the UAE Pillar Two regime. The FTA has outlined the process for registering for QDMTT purposes and provides specific guidance on the obligations that taxpayers must satisfy to ensure timely compliance with the new rules.
Our comments
The release of the guidance marks an important step in the UAE’s implementation of the OECD Pillar Two framework. By clarifying scope determination, entity classification rules, and registration procedures, the guidance provides greater certainty for in-scope MNE groups and helps businesses prepare for their Pillar Two compliance and reporting obligations in the UAE. Groups with UAE operations should assess their position under the clarified rules and ensure that appropriate registration and compliance processes are in place.