Ganesh Ramaswamy
Partner K Rangamani and Associates LLP, India
APAC region tax update
March 13, 2026
APAC region tax Q1 tax update:
Australia
Payments to associated enterprises are not deductible in the absence of contracts
On 17 February 2026, the Full Federal Court held in Commissioner of Taxation v S.N.A Group Pty Ltd [2026] FCAFC 10 that payments made to associated enterprises were not deductible because the license agreements were not legally enforceable contracts. The court stressed that payments between related entities will not be deductible unless the taxpayer can demonstrate, through objective evidence, a real, enforceable obligation to pay, supported by objective evidence of agreement and consistent conduct. The decision reinforces those informal arrangements, even if standard within a business group, require clear documentation to support tax deductibility, as “arm’s-length” pricing alone does not prove a contract exists.
China
Preferential tax treatment for depository receipts and innovative enterprises
China has extended preferential tax treatments for Chinese Depository Receipts (CDRs) and for innovative enterprises till December 31, 2027, including exemptions on income tax for individual investors and for institutional investors. Individual investors are exempt from income tax on CDR disposals, with differentiated tax rates on dividends. Institutional investors, including qualified foreign institutional investors (QFIIs) and Renminbi qualified foreign institutional investors (RQFIIs), are exempt from enterprise income tax and value-added tax (VAT) on CDR disposals and related gains. The Chinese policy is extended to foster capital market investment in specific, high-growth, innovative industries. These incentives reduce the tax burden which results in an increase of trading volumes and attracts foreign capital.
Read the latest China tax newsletter from Kreston Brighture below
Kazakhstan
Internet platform owners to comply with reporting obligations
Starting January 1, 2026, internet platform owners in Kazakhstan must submit monthly reports through the Integrated Tax Administration System (ITAS) regarding payments to resident sellers and service providers. Reports have to be filed by the fifth of the following month, requiring accurate, signed data on transactions and also with “nil” reports for inactive periods. Owners must disclose information on payments made to individuals, individual entrepreneurs, and legal entities residing in Kazakhstan. Reports must be submitted monthly, no later than the fifth day of the month following the reporting period.
Singapore
Pillar two administrative rules and registration details
In December 2025, the Singapore Government implemented the Multinational Enterprise (Minimum Tax) (Administrative Matters) Regulations 2025, detailing administrative rules for Singapore’s multinational enterprise top-up tax (MTT) and domestic top-up tax (DTT) regimes. The regulations outline qualifying conditions for designated filing entities, prescribed reporting events, record-keeping periods, and interest rules. If the €750 million threshold is met for at least two of the four fiscal years preceding January 1, 2025, registration must occur within 30 days of January 1, 2025. Companies that shifted tax residency from Singapore to a foreign jurisdiction after November 30, 2021, must also be disclosed.
Sri Lanka
The Inland Revenue Act, No. 24 of 2017 has been amended on February 24, 2026.
The key amendments include :
- Changes in capital gains tax rates.
- Relief for interest on outstanding tax liabilities.
- Acceptance of individual tax returns without further assessment.
- Reforms to the withholding tax/advance income tax regime.
- Reforms to return filing requirements and compliance obligations.
- Refund of taxes on cancelled or altered contracts.
