08 June 2026 Global Tax Policy and Controversy Watch | June 2026 edition As tax complexity intensifies, increased compliance spend is not reducing tax controversy. In "Why managing tax compliance and tax controversy should be co-sourced," EY Partners Luis Coronado and Steve Foster outline why leading tax functions are rethinking their operating models. By integrating internal expertise with external, tech-enabled capabilities, co-sourcing improves data quality, enhances transparency, and shifts teams from reactive disputes to proactive risk management — driving better outcomes, efficiency and a more sustainable approach to tax risk. The Australian Taxation Office's newly released Decision Impact Statement reflects its concern that the PepsiCo decision should not be treated as a broader constraint on future challenges involving intellectual property.
On 12 May 2026, the Australian Government announced its 2026-27 Federal Budget, introducing a package of tax measures focused on individuals, trusts and property concessions, rather than broad corporate tax reform. For businesses, the changes increase compliance complexity and may affect investment structuring, capital allocation and use of trusts, while offering targeted cashflow support and incentives for smaller and innovation-focused entities. Bill C-31, introduced on 6 May 2026, implements key amendments to Canada's Pillar Two framework, including deferring the undertaxed profits rule (UTPR) by one year to fiscal years starting after 31 December 2025. It introduces new safe harbors, the Side-by-Side Safe Harbour and Ultimate Parent Entity Safe Harbour, and extends the Transitional Country-by-Country Reporting Safe Harbour to 2028—2029. The bill also includes technical changes to the Global Minimum Tax Act. Canadian and inbound multinational groups should review compliance and planning in light of these ongoing changes. The Chilean Government submitted a comprehensive tax reform bill aimed at boosting economic growth, enhancing legal certainty and encouraging both domestic and foreign investment. The bill includes key measures such as a gradual reduction of the corporate income tax rate from 27% to 23% by 2029, a return to a fully integrated tax system by 2030 and the reintroduction of a tax stability regime for large investments. On 25 May 2026, the Portuguese Tax Authority provided guidance on implementing the OECD's updated Pillar Two filing rules from a Portuguese perspective. The OECD's 18 May 2026 update addresses compliance challenges due to delays in filing portals and information exchange agreements. Though the new guidance eases compliance for the 2024 fiscal year, Portuguese companies should carefully assess the impact on their operations and seek expert tax advice to manage the complexities of the Global Minimum Tax regime effectively. On 6 May 2026, Uruguay issued Decree No. 95/026, regulating Personal Income Tax on foreign-source investment income and capital gains. The decree introduces detailed rules for taxable income determination, including real and simplified methods, revised income timing, expanded loss use and foreign tax credits. It confirms a 12% tax rate (6% for some taxpayers) on foreign capital income and gains, broadens taxable dividend scope, and establishes withholding and advance payments starting 2026. These changes increase compliance complexity and planning needs for taxpayers with foreign assets.
Document ID: 2026-1225 | ||||
