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Cyprus raised its corporate income tax rate from 12.5% to 15% at the start of 2026. The change aligns the island with the OECD global minimum. It is part of the most significant reform of the Cypriot tax system this century. However, the rate increase is only one element of a much wider package. The 15% headline rate is still among the most competitive in the EU. Moreover, the government kept three key regimes for international holding, financing and IP companies. These are the IP Box, the Notional Interest Deduction (NID) and the holding company framework. As a result, investors can still plan for the long term in Cyprus. The IP Box Under the IP Box, 80% of qualifying profit from qualifying intellectual property is exempt. Patented inventions and copyrighted software are examples. Therefore, only the remaining 20% is taxed, which gives an effective rate of about 3%. The regime follows the OECD modified nexus approach. This means the benefit is proportionate to the qualifying development spending that the Cyprus company actually incurs. In addition, the 120% deduction for qualifying R&D expenditure now runs until 2030. The Notional Interest Deduction The NID is a key...

On 3 September 2026, the Court of Justice of the EU (CJEU) ruled in Case C-798/24, Jautiva. The question was simple. Can shareholders' personal data in public companies be open to everyone, with no conditions? The ruling balances business transparency against privacy and data protection. How the case arose The case began with constitutional complaints from 17 minority shareholders in Latvia. They challenged a law under which shareholder information was published online for anyone to see. For natural persons, this covered identity and contact details. In addition, the law disclosed share class, number and nominal value, plus voting rights. Access did not depend on showing a legitimate interest. The Latvian legislature named several objectives. One was protecting third parties through greater business transparency. It also cited the prevention of money laundering and terrorist and proliferation financing. Another aim was to implement restrictive measures. For this reason, Latvia's Constitutional Court asked the CJEU to interpret EU company and data protection law. What the Court decided on the company law directive First, the Court looked at Article 14(d) of Directive (EU)...

Malta is changing its VAT rules for gambling from 1 October 2026. Legal Notice 86 of 2026 amends the VAT Act. Meanwhile, the Malta Tax and Customs Administration (MTCA) has published guidelines listing the exempt supplies. The MTCA and the Malta Gaming Authority (MGA) announced the reform on 2 April 2026. The reform has three aims. It clarifies the scope of the exemption. In addition, it taxes services where they are consumed. Finally, it keeps VAT neutral for operators. So operators should check which category each of their services falls into. The position up to 30 September 2026 Until now, betting, lotteries and other gambling were exempt without credit. This follows from item 9 of Part Two of the Fifth Schedule to the VAT Act. No VAT was charged on these supplies. Input VAT attributable to them could not be deducted either. What changes from 1 October 2026 Legal Notice 86 amends that item. Now the exemption applies only to gambling approved by the Minister. The MTCA guidelines list the approved categories. If a supply is not on the list, it is not exempt. Under the guidelines, the following stay exempt: low-risk games, as defined in the Fifth Schedule to the Gaming...

On 4 September 2026, the Cyprus Registrar of Companies announced an extension. Cyprus companies can now file overdue annual returns and financial statements until 31 December 2026. The extension follows an earlier reminder exercise. As a result, companies with a backlog have a chance to put their records in order without rushing. What the extension covers The notice applies only to overdue annual returns and the related financial statements. However, strike-off under section 327 of the Companies Law will continue. It will affect companies that remain non-compliant after the deadline. That said, companies will not disappear from the register automatically on 1 January. Strike-off is a legal process with separate steps. In addition, the extension does not remove other obligations. It does not postpone tax or beneficial ownership duties. Penalties also stay in place unless the notice expressly says otherwise. Where to start First, confirm which filings are actually outstanding. The company's age or the last invoice from its service provider is not a reliable guide. Then work backwards from the filing date. If the records are complete, a return can be ready quickly. If several...

On 1 October 2026, the Swiss Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (LETA) entered into force. Switzerland is introducing a central register of beneficial owners for the first time. What changes Until now, companies were only expected to keep an internal register of their beneficial owners. They are now required to: identify their beneficial owners; document how those owners exercise control; report certain information about them to a new federal register run by the Federal Office of Justice. Who is affected The rules are not limited to Swiss entities. Certain foreign companies with a sufficient connection to Switzerland are also covered, whether through a branch, real estate holdings or effective management in Switzerland. What companies should do LETA tightens requirements on governance, documentation and compliance, and responsibility sits with the companies and their governing bodies. Companies should work out which of the new obligations apply to them and make sure their internal processes are robust enough to meet the requirements within the applicable timeframes. Source: Borel &...

The UK Information Commissioner's Office (ICO) has published a report on a citizens' jury about neurotechnology and neurodata. The findings will inform the ICO's upcoming guidance on how data protection law applies to devices that record or send electrical signals to the brain and nervous system. The sector is growing fast: the UK has 54 dedicated neurotech companies with nearly £120 million in turnover and more than £200 million in investment. How the jury worked Nesta's Centre for Collective Intelligence brought together 20 UK residents for three online sessions over two weeks in March 2026. Jurors watched specialist videos, heard from experts and discussed how to get the benefits of neurotech while managing the risks. The findings are qualitative and are not meant to represent wider public opinion. Key findings Jurors were broadly supportive of medical, wellbeing and workplace-safety uses, such as devices that help manage pain or track driver fatigue. They strongly opposed using neurodata to monitor employee focus or student productivity. Their main concerns were discrimination, since a "normal" range of brain activity could penalise older people, neurodiverse people and...

Transfer pricing enquiries in the UK are getting longer, larger and more contentious. According to law firm Macfarlanes, HMRC's transfer pricing yield rose to £3.4bn in 2024/25, nearly double the previous year, while the number of settled enquiries stayed roughly flat. The average age of settled enquiries exceeded 40 months for the first time. HMRC's own targets are much shorter: 18 months for most cases and 36 months for complex or high-risk ones. How HMRC selects and runs enquiries HMRC openly says it picks transactions to enquire into largely based on the amount of tax at risk. Initial requests aim to understand how the business trades, who performs which functions, what intra-group transactions exist and where profit arises. In practice, the requests rarely stop there. HMRC goes on to interview key individuals and review contemporaneous documents such as emails. What HMRC can require from a taxpayer Information must be reasonably required to check the taxpayer's tax position. HMRC does not need to suspect a loss of tax, but it cannot go on a fishing expedition, and disproportionate requests are unlikely to qualify. The taxpayer only has to produce what is within its...

Ukraine has joined the Addendum to the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (CRS MCAA Addendum). The Addendum provides the international legal basis for exchanging an expanded set of data under the updated Common Reporting Standard (CRS). What this means for Ukraine Ukraine's tax authorities will be able to receive more complete and better-structured information from foreign counterparts about financial accounts held abroad by Ukrainian tax residents. This will help the State Tax Service to: detect undeclared foreign income; identify account holders and controlling persons more accurately; improve the quality of tax risk analysis; counter tax evasion and the offshoring of income more effectively; ensure a level playing field for taxpayers who comply voluntarily. Why the standard was updated The OECD approved the updated CRS in 2023 following a comprehensive review that took into account developments in the financial sector, new financial products and practical experience. The changes cover new instruments that can serve as alternatives to traditional financial products, clarify the information to be...

HM Revenue & Customs (HMRC) has outlined key principles in its Capital Gains Manual (CG25000C) detailing how an individual's tax residence, ordinary residence, and domicile status determine their liability to UK Capital Gains Tax (CGT).The statutory framework aims to charge CGT on gains where there is a sufficient territorial connection between the individual realizing the gain and the United Kingdom.Key Highlights:UK Residents: Individuals who are UK tax residents are generally subject to CGT on their worldwide capital gains, subject to the remittance basis for non-domiciled individuals and relevant Double Taxation Treaties.Non-UK Residents and UK Property:Since April 6, 2015, non-residents disposing of UK residential property interests fall within the scope of CGT.Since April 6, 2019, the scope was expanded to cover direct and indirect disposals of all UK land and real property (including commercial property).Trade via UK Branch or Agency: Non-residents carrying on a trade, profession, or vocation in the UK through a branch or agency remain chargeable on gains from assets used for the purpose of that business.Temporary Non-Residence Rules: Anti-avoidance provisions ensure...