Global Minimum Tax Implementation Acceleration
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Japan: Introduces QDMTT and UTPR from April 2026, complementing existing IIR, alongside 4% defense surtax increasing effective rate by ~0.9%.
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Iceland: Plans March 2025 introduction of 15% minimum tax legislation for €750M+ MNE groups.
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Denmark: Consults on Pillar 2 administrative guidelines, Amount B implementation, and transfer pricing relief for SMEs.
Green Economy Tax Engineering
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Denmark: Launches “green investment window” offering 108% depreciation basis for climate-friendly investments through 2026, excluding fossil fuel-powered assets.
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Belgium: Proposes 40% harmonized investment deduction for energy, mobility, and environmental assets from 2026.
Cross-Border Trade Dynamics
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US: Pauses 25% Canada/Mexico tariffs for one month pending border security commitments; 10% China tariff remains pending.
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Belgium: Plans Digital Services Tax by 2027 if no EU/international agreement reached.
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Canada: Defers capital gains inclusion rate increase to 66.7% until 2026 for gains above CAD 250,000.
Domestic Tax Structure Modernization
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Belgium: Transforms dividend deduction into full participation exemption with €4M investment threshold, introduces 10% solidarity tax on financial asset gains above €10M.
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Hungary: Raises VAT exemption threshold to HUF 18M, allows retroactive option through February 2025.
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India: Extends start-up tax exemption to 2030, introduces 3-year block transfer pricing regime.
Digital Asset Regulation
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Slovak Republic: Approves DAC8 implementation for crypto-asset reporting starting 2026, with full compliance by 2028.
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Belgium: Includes crypto assets in new 10% solidarity tax framework with tiered exemptions.
Insights:
This week’s developments reveal an accelerating convergence of environmental and tax policy, with Denmark and Belgium leading innovative approaches to incentivize green investments while carefully defining exclusions to prevent greenwashing.
The emerging pattern of delayed implementation for contentious measures, exemplified by Canada’s capital gains deferral and the U.S. tariff pause, suggests growing recognition of the need to balance policy objectives with economic stability.
The contrasting approaches to digital economy taxation – from Belgium’s standalone DST threat to coordinated crypto-asset reporting – highlight the tension between national sovereignty and international harmonization in an increasingly digital global economy.
These trends signal a shift toward more sophisticated, multi-layered tax policies that attempt to balance domestic priorities, international commitments, and economic transformation imperatives.
