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In Tax

United States: Proposed regulations would source borrow fees to the residence of the recipient

by and 4 Mins Read

On 10 December 2025, the IRS and Treasury announced forthcoming proposed regulations to address the sourcing of borrow fees in securities lending and sale-repurchase transactions. The proposed rules will source borrow fees to the residence of the recipient, generally exempting non-US securities lenders from US withholding tax.
The guidance applies to transactions documented under standard industry agreements and defines borrow fees broadly, including negative rebates, while excluding bespoke arrangements.
Taxpayers may rely on the Notice immediately, with the regulations applying prospectively to taxable years ending after publication in the Federal Register

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In AML & Financial Services Regulatory

European Union: SFDR 2.0 — simplified disclosures, new categories and stricter marketing rules

by , , and 4 Mins Read

On 20 November 2025, the European Commission proposed major changes to the Sustainable Finance Disclosure Regulation (SFDR) to simplify disclosures and strengthen investor protection. The new framework introduces three product categories—Transition, Sustainable, and ESG Basics—each requiring a 70% investment commitment and exclusion of harmful industries. Simplified two-page templates will replace current disclosure rules, and entity-level obligations like principal adverse impacts are removed.
Only products in these categories may use sustainability-related terms in marketing. Taxonomy disclosures become optional, with a 15% safe harbor for aligned assets. Application is expected 18 months after adoption, likely in 2028, marking a significant shift toward clearer, stricter sustainability standards.

In Tax

United States: White House publishes plan for the taxation of cryptocurrencies and other digital assets

by , and 1 Min Read

Earlier this summer, the US Administration’s Working Group on Digital Asset Markets published a report, entitled Strengthening American Leadership in Digital Financial Technology. The Report contains recommendations for revising existing legislation and IRS guidance regarding trusts engaged in cryptocurrency staking, Code provisions that may deny recognition of gains or losses by active securities traders, and reporting requirements for participants in digital asset transactions and for the exchanges that facilitate such activities

In Tax

Ukraine: Approval of Defence City regime for arms manufacturers including tax and customs incentives

by 2 Mins Read

Ukraine’s Defence City regime, effective from October 2025, offers tax, customs, and regulatory incentives to defence-related enterprises. Eligible companies must earn most income from defence goods or services. Benefits include exemptions on reinvested profits, real estate, land, and environmental taxes, plus simplified customs and currency rules. However, it excludes R&D credits and broader investor incentives, and cannot be combined with other preferential regimes. Residency is limited to strategically significant entities approved by the Ministry of Defence.

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In Tax

United States: After the Federal Circuit IEEPA tariff ruling, what comes next?

by , and 4 Mins Read

On August 29, 2025, the US Court of Appeals for the Federal Circuit (CAFC) issued a 7-4 en banc opinion in VOS Selections, Inc. v. Trump, holding that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose broad, indefinite tariffs. The case was initially brought in the Court of International Trade (CIT) by private businesses and the US state attorneys general. The President invoked IEEPA on various grounds, including concerns about drug enforcement, border security, and trade deficits. In a May decision granting summary judgment to the VOS Selections plaintiffs, the CIT found that IEEPA does not authorize the President to impose the tariffs at issue, which the US Government appealed.

In Tax

United States: The One Big Beautiful Bill Act (OBBBA) changes the capitalized interest rules under section 163(j)

by 1 Min Read

The One Big Beautiful Bill Act makes three major changes to the interest deduction limitation provision of §163(j). Pub. L. No. 119-21, §70303, §70341 (July 4, 2025), applicable to taxable years beginning after December 31, 2024. This article reviews the three changes and then focuses on the new rule for capitalized interest.

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In Tax

China – Ticking clock: Navigating China’s new tax-related information reporting regime for online platforms

by , , and 2 Mins Read

China has introduced a new tax reporting regime requiring internet platforms—both domestic and overseas—to regularly report tax-related information to Chinese authorities. This move, under State Council Decree No. 810 and STA Bulletin [2025] No. 15, aims to close tax loopholes and enforce compliance. Platforms must now implement robust systems to meet these obligations, with significant implications for data privacy and cross-border data transfers.

In Anti-Corruption

United States: Spring brings CTA reporting deadline

by , and 3 Mins Read

As of 18 February 2025, the US Treasury’s Financial Crimes Enforcement Network is once again authorized to enforce the beneficial owner interest (BOI) reporting provisions of the Corporate Transparency Act . Therefore, beneficial ownership interest report filing by Reporting Companies is once again mandatory with an extended deadline of March 21, 2025, for many companies.

In Corporate Compliance

Hong Kong: Proposed re-domiciliation regime

by , , , and 8 Mins Read

On 20 December 2024, the Hong Kong government gazetted the Companies (Amendment) (No.2) Bill 2024 (“Bill”) which introduces Hong Kong’s long awaited inward re-domiciliation regime. The Bill was introduced to the Legislative Council on 8 January 2025 and once enacted, will enable non-Hong Kong incorporated companies to relocate their domicile to Hong Kong, while maintaining their legal identity and business continuity.

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