10 February 2026

Global Tax Policy and Controversy Watch | February 2026 edition

Spotlight

You're invited to join our panelists in exploring the findings from the 2025 EY Tax Risk & Controversy Survey. Learn how leading multinationals are reshaping their tax strategies — moving from reactive dispute resolution to proactive readiness powered by technology and strong governance frameworks. Two sessions of this webcast are available, each featuring similar content tailored to regional nuances: Tuesday, 24 February at 10:00-11:00 a.m. EST, and Wednesday, 25 February at 3:00-4:00 p.m. Beijing/Hong Kong Time.

The pace of global change is relentless, and decisions rarely occur in isolation. Leaders worldwide are navigating a complex web of competing priorities. Join a panel of EY professionals from around the world, on Thursday, 5 March at 10:00-11:30 a.m. EST, as they kick off the 2026 EY Tax Policy and Controversy Outlook series, exploring changing global tax policies and what businesses can do to prepare.

Key highlights

On 15 January 2026, the Supreme Court of India ruled that capital gains from a Mauritius-based investment fund's indirect share transfer are ineligible for tax-treaty exemptions, emphasizing the need for substantial commercial activity. Affected entities should reassess their investment structures to align with this interpretation.

In Sirius Solutions v. Commissioner, the Fifth Circuit ruled that a "limited partner" under IRC Section 1402(a)(13) refers to a limited partner in a state-law limited partnership with limited liability. The court rejected the Internal Revenue Service's "passive investor" rule and the Tax Court's "functional analysis" test, though the issue remains unresolved for taxpayers.

Electronic invoicing (e-invoicing) has emerged as a critical focus for businesses worldwide, driven by the rapid adoption of mandatory regulations across various regions. Use the EY global E-invoicing Developments Tracker to stay informed and help empower your organization to adapt swiftly to the changing landscape of global tax compliance.

News

On 20 January 2026, the Organisation for Economic Co-operation and Development (OECD) hosted a public consultation on global mobility of individuals, during which the OECD Secretariat, tax officials from countries around the world, business representatives and others provided perspectives on the rise of global mobility and tax issues that can impede the opportunities and growth that global mobility drives.

On 31 December 2025, Cyprus enacted significant tax reform measures aimed at stimulating economic growth and enhancing tax compliance, with most changes effective from 1 January 2026. The corporate income tax rate will increase from 12.5% to 15% and deemed distributions rules are abolished. The reforms introduce new dividend withholding tax rates, special rules for cryptocurrency profits and stock options, increase penalties for noncompliance and expand the scope of capital gains tax, requiring companies to reassess their tax planning and compliance processes.

On 12 January 2026, Guatemala became the 148th member of the OECD/G20 Inclusive Framework on BEPS, reinforcing the country's commitment to international tax cooperation and the battle against base erosion and profit shifting (BEPS).

On 1 February 2025, the Finance Minister of India unveiled the Union Budget, outlining significant reforms aimed at enhancing the business environment. Key proposals include a new Income Tax Bill designed for clarity, alongside tax law changes that foster certainty, reduce litigation and encourage investment in the International Financial Service Center. Additionally, the budget introduces a simplified transfer pricing process to address controversies and expand safe harbor provisions.

The Luxembourg government has proposed draft legislation to implement individualized taxation through a single tax class, replacing joint taxation for married couples and registered partners. The reform aims to enhance child-related tax benefits, increase deductibility limits and simplify tax refund procedures, promoting neutrality and predictability for taxpayers.

On 12 January 2026, Oman issued Royal Decree No. 8/2026, establishing the International Financial Centre of Oman (IFC Oman), effective immediately. IFC Oman will provide income tax exemptions, nonresident tax relief and VAT benefits. Businesses and investors should stay informed on regulatory updates and assess potential advantages.

Saudi Arabia's Ministerial Resolution No. 468, published on 16 January 2026, introduces Implementing Regulations for Special Economic Zones (SEZs), effective 90 days post-publication. The Regulations provide tax and customs incentives and establish licensing requirements for four SEZs. Businesses should review their structures to comply with these new regulations.

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Contact Information

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Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

Document ID: 2026-0402