Global Tax Updates April 2026: APA, Stock Buyback, Belgium CGT
Multinational businesses and cross-border taxpayers face a rapid-fire month of regulatory changes. The global tax updates april 2026 we track in this briefing — sourced from Deloitte’s World Tax Advisor issue dated 17 April 2026 — touch transfer pricing, capital gains regimes, R&D incentives, advance pricing agreements, and excise taxes on stock buybacks. Whether you run a U.S. parent with overseas subsidiaries or advise inbound investors, here is what matters this month. 🌐
United States: 2025 APA Report — what changed? 🇺🇸
The IRS released the 2025 Advance Pricing and Mutual Agreement (APMA) Program report showing APA execution dropped year-over-year while inventory rose, and India remained the top bilateral APA (BAPA) treaty partner.
For multinationals pursuing transfer-pricing certainty, the takeaway is that APA processing times are likely to stretch further through 2026–2027. If your intercompany arrangements involve India, Japan, or Canada, the bilateral pipeline is congested. In our Los Angeles practice we advise U.S. parents to (1) file amended APA renewals earlier than the nominal expiration date, (2) revisit functional analyses to reduce TP risk in the gap, and (3) document contemporaneous pricing carefully even while the APA is pending. See the IRS APMA program page for filing procedures.
United States: Final stock buyback excise tax regulations — M&A impact? 📉
Treasury and IRS finalized regulations governing the 1% excise tax on stock repurchases by publicly traded corporations, with significant implications for taxable acquisitions, SPAC de-mergers, cross-border redemptions, and non-standard equity transactions.
The final rules clarify the “netting rule” (issuances during the year reduce the base), the treatment of mergers where the acquirer stock is used, and the funding rule that can pull foreign parent repurchases into U.S. excise tax if a U.S. subsidiary funds the buyback. For M&A deal teams, the practical impact is that valuation models must now separately line-item the excise tax on any taxable-cash deal, and tax insurance policies are adjusting their exclusion language.
We advise clients closing a taxable stock acquisition in 2026 to model the 1% excise tax on a target-by-target basis and consider timing issuances of comparable value within the same tax year to take advantage of the netting rule. For inbound foreign parents, the funding rule trap is real — document any intercompany cash flow used to finance U.S. repurchases.
Belgium: New capital gains tax on financial assets — who’s affected? 🇧🇪
The Belgian parliament adopted a new capital gains tax regime on financial assets effective January 1, 2026, applying to individuals and certain non-profit entities, with a withholding tax component activating for certain gains from June 1, 2026.
This is a landmark shift for Belgium, historically a friendly jurisdiction for private investor capital gains. U.S. expats residing in Belgium and Belgian nationals holding U.S.-listed securities should reassess brokerage account reporting and coordinate with U.S. tax filing to claim foreign tax credits on the Belgian tax paid.
United Arab Emirates: R&D tax credit launches — how to qualify? 🇦🇪
The UAE Ministry of Finance issued ministerial decisions establishing a research and development tax credit regime under UAE corporate tax law, effective for tax periods beginning on or after January 1, 2026.
The UAE R&D credit is structured as a percentage of qualifying expenditure on domestic research and development activities. For multinationals with innovation hubs in Dubai or Abu Dhabi, this is a meaningful supplement to the zero or low effective tax rate in free zones. Coordination with U.S. Section 174 capitalization rules (and the revised amortization schedule under OBBBA) is essential to avoid double-capturing the same R&D cost.
Norway: Supreme Court ruling on thin capitalization and transfer pricing 🇳🇴
Norway’s Supreme Court ruled that an arm’s-length transfer pricing adjustment for thin capitalization cases must be determined on a net basis — considering both the thin cap and the arm’s-length interest rate — rather than on a gross basis (thin cap only).
The decision aligns Norwegian TP practice more closely with the OECD Transfer Pricing Guidelines and places a higher evidentiary burden on Norwegian tax authorities to show the most likely arm’s-length outcome rather than any defensible figure within a range. For Nordic MNEs with intercompany loan arrangements, this is a positive development and a good moment to refresh benchmarking studies.
Australia: Retroactive foreign-resident CGT changes 🇦🇺
The Australian government released exposure draft legislation on the foreign resident capital gains tax regime that would apply retroactively — a significant departure from earlier signals during the 2024–25 Federal Budget announcements.
The draft affects foreign residents holding Australian real-property interests (including interests in land-rich entities). The retroactive feature is the concerning element: transactions structured pre-announcement under then-current law may be re-characterized. Taxpayers with recent or pending divestitures of Australian real estate or land-rich equity holdings should seek urgent Australian tax advice and consider formal submissions during the consultation period.
The Philippines also issued a new circular clarifying taxation of cross-border services by nonresidents, and Hong Kong gazetted a draft bill enhancing administrative enforcement of its Common Reporting Standard (AEOI) regime effective January 1, 2027. If you operate in Asia-Pacific, both are on the near-term radar and require information-reporting review now, not later.
Quick summary: the global tax updates april 2026 action list 📋
| Jurisdiction | What Changed | Who Should Act |
|---|---|---|
| United States | 2025 APA report released; final stock buyback excise tax rules | MNEs w/ bilateral APAs; public M&A deal teams |
| Belgium | CGT on financial assets from 1 Jan 2026 | Individual investors; expats in Belgium |
| UAE | R&D tax credit regime launched | Tech / innovation MNEs |
| Norway | Supreme Court TP ruling on thin cap | Groups w/ Norwegian intercompany debt |
| Australia | Retroactive foreign-resident CGT draft | Foreign holders of Australian real property |
| Hong Kong | Draft AEOI enforcement enhancements | Reporting financial institutions |
| Philippines | Clarified taxation of cross-border services | Nonresident service providers |
