Sonja Alvermann
Germany VAT Specialist
Germany
July 31, 2026
July 31, 2026
July 14, 2026
As international mobility, cross-border investment and remote working continue to reshape the global business environment, understanding the tax implications of operating across jurisdictions has never been more important. Spain remains one of Europe’s most attractive destinations for foreign investors, professionals, retirees and property owners, making it essential for non-residents to understand the country’s tax framework before establishing financial or personal ties.
The Non-Residents Guide – Spain 2026, produced by Kreston Iberaudit, provides a practical overview of the Spanish tax rules affecting individuals and entities that are not tax resident in Spain but derive income from Spanish sources or own assets within the country. Based on legislation and administrative guidance in force from 1 January 2026, the guide combines technical expertise with practical examples to help readers navigate a complex tax environment. Click here to download the guide in full, or read a summary down below.
The first step in determining any tax obligation is establishing residency status. The guide explains the criteria used by the Spanish authorities to determine whether an individual or business is considered a tax resident, including physical presence, economic interests and family ties. It also explores how Spain’s network of Double Taxation Agreements (DTAs) helps prevent double taxation and resolves cases where an individual could be regarded as resident in more than one country.
International employment arrangements have become increasingly common, creating new tax considerations for both employers and employees. The guide examines the taxation of employment income, pensions and cross-border remote working, clarifying when income is taxable in Spain and how treaty provisions may apply. It also provides a comprehensive overview of Spain’s Special Impatriate Regime, commonly known as the “Beckham Law”, outlining the eligibility criteria and potential tax advantages available to qualifying professionals, entrepreneurs and international talent relocating to Spain.
For investors, the guide explains how Spain taxes dividends, interest and royalties, together with the exemptions available under domestic legislation and EU directives. It also explores withholding tax obligations and the importance of Double Taxation Agreements in determining the final tax burden.
The publication also provides practical guidance for those owning or investing in Spanish real estate. Topics include the taxation of rental income, imputed income on unoccupied properties, capital gains on disposal, VAT, Wealth Tax and municipal taxes, as well as the withholding requirements that apply when non-residents sell Spanish property.
Beyond property transactions, the guide examines the taxation of capital gains arising from shares, securities and other investments, highlighting how domestic legislation interacts with international tax treaties. It also covers several practical administrative matters that non-residents frequently encounter, including obtaining a Spanish Foreigner Identification Number (NIE), appointing tax representatives where required and meeting ongoing compliance obligations.
Readers will find practical guidance on:
Whether you are relocating to Spain, investing in Spanish assets, employing international talent or advising globally mobile clients, the Non-Residents Guide – Spain 2026 offers a comprehensive overview of Spain’s tax framework for non-residents. Designed as both a technical reference and a practical resource, it helps readers better understand their obligations and identify the issues that should be considered before making investment or relocation decisions. For more detailed analysis, examples and country-specific guidance, readers are encouraged to download the full guide.
In this article for Bloomberg Tax, Jelena Mihic (Kreston MDM and Chair of the Europe Regional Committee) explores how the U.S. exemption from the OECD’s global minimum tax rules could reshape the future of global tax policy. The OECD’s Pillar Two framework introduced a 15% global minimum tax to reduce profit shifting, curb harmful tax competition, and create a more consistent international tax system for multinational groups with revenues exceeding €750 million. Read the full article here, or a summary below.
While the United States shares these objectives through its Global Intangible Low-Taxed Income (GILTI) regime, the two systems differ significantly. GILTI applies a lower effective tax rate and uses a global blending approach rather than the jurisdiction-by-jurisdiction methodology required under Pillar Two. As a result, it does not fully comply with the OECD rules.
Recognising the political challenges of reforming U.S. tax legislation, the OECD has temporarily accepted GILTI as “broadly equivalent.” This pragmatic decision helps maintain U.S. participation in the global framework but moves the initiative away from the uniform model originally agreed in 2021.
The U.S. exemption introduces greater flexibility but also creates uncertainty about the long-term consistency of the global minimum tax. Other countries may seek recognition for their own domestic minimum tax regimes, leading to a more fragmented landscape where multiple, interoperable systems coexist rather than a single global standard.
For EU-based multinational groups, the implications are significant. Companies remain subject to the full Pillar Two requirements, including comprehensive GloBE calculations, jurisdiction-specific top-up tax assessments, and extensive reporting obligations. Meanwhile, many U.S. groups continue operating under GILTI without equivalent compliance requirements, creating competitive and administrative disparities.
The evolving framework is also likely to influence investment decisions, as the benefits of locating operations in traditionally low-tax jurisdictions are reduced once top-up taxes apply. Businesses should expect increasing complexity as different countries adopt varying approaches while remaining broadly aligned with OECD principles.
Despite the introduction of the global minimum tax, transfer pricing remains fundamental to international tax planning. Pillar Two calculations continue to rely on transfer pricing outcomes to determine where profits arise and whether additional tax is payable.
Tax authorities are expected to place greater emphasis on economic substance, including DEMPE functions, supply chain design, workforce location, and operational activities. Robust transfer pricing documentation will therefore play an increasingly important role in supporting Pillar Two positions and defending tax outcomes during audits.
Looking ahead, multinational groups should move beyond compliance and adopt an integrated tax and transfer pricing strategy. Organisations that proactively review their operating models, strengthen economic substance, and align transfer pricing with the evolving global tax environment will be best positioned to manage risk and remain competitive as the international framework continues to develop.
July 10, 2026
Kreston Global member firms Kreston Reeves (UK) and Kreston ProWorks (Japan) have successfully advised Washin Chemical Industry Co., Ltd. on its acquisition of JFBR Group Limited, the holding company of Foilco Ltd. Read the full report here, or a summary below.
Headquartered in Japan, Washin Chemical Industry Co., Ltd. manufactures hot stamping foils and specialist coatings and paints for products and consumer packaging worldwide. Founded in Greater Manchester in 1987, Foilco Ltd. is a leading supplier of hot stamping foils for premium packaging, print and product decoration.
Working collaboratively across borders, Kreston Reeves and Kreston ProWorks delivered a seamless, multilingual advisory service covering buy-side corporate finance, financial due diligence and tax due diligence. The transaction also drew on the expertise of Kreston Revicom (Italy), which provided specialist local tax advice, demonstrating the strength of the Kreston Global network in supporting complex international transactions.
Craig Dallender, Corporate Finance Director at Kreston Reeves, said: “Kreston Reeves and the Kreston Global network is well-placed to support businesses anywhere in the world looking to do business in the UK or to acquire UK businesses. We are delighted to have advised the Washin Chemical Industry Company on this acquisition and to work alongside the terrific Kreston ProWorks team. This transaction really demonstrates the strength of Kreston Global and our ability to leverage regional expertise and vast deal experience to provide our clients with high quality cross-border support.”
Marek Lehocky, CEO and Director of Kreston ProWorks, said: “Washin Chemical Industry Company is a global leader in specialist foils and coatings with customers around the world. Its acquisition of Foilco Ltd in the UK is an important step in its international growth, and we are pleased to have supported this transaction alongside Kreston Reeves. We also appreciate the role of Nihon M&A Center, a leading M&A advisory and brokerage firm, in bringing the buyer and seller together and enabling this successful cross-border transaction.”
Andrew Griggs, Senior Partner and Head of Global at Kreston Reeves, added: “This engagement clearly demonstrates the strength of the Kreston Global network and how our member firms collaborate seamlessly to deliver effective cross-border solutions for clients. I am extremely proud of the way Kreston Reeves and Kreston Proworks worked together as one team to successfully support a mutual client.”
Shin Nakamichi, Executive Officer, Washin Chemical Industry Co., Ltd., said: “We are grateful for the support provided by Kreston Reeves and Kreston ProWorks throughout this acquisition. Their advice was timely, practical and well coordinated across Japan and the UK, which gave us confidence as we progressed the transaction.”
Legal advice to Washin Chemical Industry Co., Ltd. was provided by Nishimura & Asahi and RPC Legal, while Lodders Solicitors advised Foilco Ltd. Japanese corporate finance advice was also provided by Nihon M&A Center Inc. For more information on doing business with Kreston Global, please contact us here.
June 18, 2026
Electronic invoicing and “VAT in the Digital Age”, or ViDA for short, is gaining rapid traction across Europe and beyond. What was once seen as a technical or administrative improvement is now becoming a central pillar of tax compliance. This transformation is at the heart of the European directive, which aims to modernise the VAT system and align it with today’s digital economy.
But what does this mean in practice?
An electronic invoice is often conceptualised as a PDF sent by email. However, under the new rules, this is no longer sufficient. The focus is shifting to structured electronic invoices: invoices created in a machine-readable format, typically an XML, which allows for the automatic processing between systems without manual intervention. This ensures that invoice data can flow directly from the supplier’s system to the customer’s accounting software, reducing errors and increasing efficiency.
Across Europe, a common standard is emerging. Many countries, including Belgium, are adopting the Peppol network, a secure framework that allows businesses to exchange structured invoices in a standardised way. Within the broader ViDA framework, this shift will become even more significant in the future. From 1 July 2030, e-invoicing and digital reporting are also expected to become mandatory for cross-border transactions within the EU.
The move towards e-invoicing is driven by both tax policy and business efficiency.
From a tax perspective, one of the key objectives is reducing the VAT gap. This gap represents the difference between the VAT that should have been collected and what is actually received by tax authorities. Across the EU, this gap amounts to billions of euros lost each year, often due to fraud, errors, or incomplete reporting. Structured e-invoicing creates a clear and reliable audit trail for each transaction, making it easier for authorities to monitor compliance.
At the same time, the benefits for businesses are significant. Invoicing automation reduces manual work, lowers administrative costs, and minimises the risk of errors. Invoices can be processed faster, which often leads to quicker payments and improved cash flow. In addition, the elimination of paper contributes to more sustainable business practices. E-invoicing is therefore not only a compliance requirement, but also an opportunity for companies to streamline their operations and support their digital transformation.
As a Belgian-based firm, we are experiencing these changes first-hand. Belgium has taken a proactive approach by introducing mandatory structured e-invoicing for domestic B2B transactions as from 1 January 2026. In practice, this means that companies established in Belgium, as well as foreign companies with a fixed establishment for VAT purposes in Belgium, must issue and receive invoices via a structured format, typically through the Peppol network.
The Belgian implementation is being rolled out in phases. At this stage, there is no real-time reporting to the tax authorities yet. However, this is expected to follow in a later phase, likely around 2028, in line with broader European developments.
From our daily practice, we see that businesses are actively preparing for these changes. This includes reviewing their invoicing processes, updating their systems, and ensuring that their data is complete and accurate. While the transition requires effort, it also creates an opportunity to improve internal processes and reduce administrative burdens in the long term.
The transition to e-invoicing marks a significant shift in how VAT compliance is managed. With many of these changes already in place or approaching quickly, supporting our clients in adapting to these new requirements is one of the top priorities in our daily work. The combination of national initiatives and broader European or international reforms, such as ViDA, makes this a dynamic and evolving landscape, that needs consistent monitoring.
You can contact us directly at Kreston MDS or email [email protected] .
The European Commission is preparing a new initiative that could significantly reshape the way companies operate across the European Union: the introduction of a new legal entity known as EU–INC. This proposal forms part of a broader ambition to reduce fragmentation within the single market and create a more unified business environment for European startups and scale-ups.
Although the proposal has not yet been formally submitted to the European Parliament or the Council, it is already gaining attention within EU institutions and among industry stakeholders. Many see it as a potential cornerstone of what is being referred to in Brussels as the “28th regime”, a single, EU-wide framework that operates alongside existing national systems.
EU–INC is a proposed pan-European company form that businesses can choose instead of incorporating under national laws. It would function as a private limited liability company with shareholder liability limited to their investment.
Its main feature is EU-level standardisation. Companies would operate under one unified framework for governance, capital structure, and investor relations, rather than navigating 27 national systems.
Key elements include:
On the other hand, companies would remain subject to local tax and employment laws.
As highlighted by Commission President Ursula von der Leyen, European companies still encounter “too many national barriers” compared to their counterparts in more integrated markets such as the United States. Differences in company law, taxation, and administrative processes across borders create complexity and cost, particularly for startups looking to upscale.
If implemented successfully, EU–INC could:
Altogether, these elements could strengthen Europe’s competitiveness and support the growth of a more integrated innovation ecosystem.
While the proposal is ambitious, it is not without risks. One key concern is that similar initiatives have struggled in the past.
The Societas Europaea (SE) was introduced to provide a European company form, but its adoption has been limited. Many companies found it complex and not sufficiently advantageous compared to national structures. There is a risk that EU–INC could face similar challenges if it does not offer clear and practical benefits.
In addition, while corporate rules may be harmonised, taxation and employment law remain national, which may still create complexity. Most importantly, the success of EU–INC will depend heavily on political alignment and implementation. Without strong support from Member States, the initiative may face delays or dilution.
At this stage, EU–INC remains a proposal under development. Both the European Council and the European Parliament have expressed interest in the concept of a “28th regime,” indicating political momentum behind the initiative. However, the formal legislative process has not yet begun.
The success of the initiative will depend on careful design and strong political support. As developments continue, EU–INC is certainly a proposal worth following closely.
Contact Kreston MDS today at [email protected]
May 15, 2026
May 1, 2026
April 24, 2026
Germany’s R&D Tax Relief Regime is driven by the Research Allowance Act, offering tax incentives for research and development in the form of an allowance. Introduced on January 1, 2020, to supplement the existing project funding, the scope of the maximum funding has recently been significantly expanded up to a maximum amount of EUR 4.2 Million per year for SMEs and EUR 3.0 Million for other entities.
The research allowance is intended to strengthen Germany as a business location, improve Germany’s attractiveness for new settlements and investment decisions, and thus secure growth and employment.
March 16, 2026
March 5, 2026
February 27, 2026
January 22, 2026
October 29, 2025
October 21, 2025
October 15, 2025
The EU’s Omnibus Package on ESG signifies a strategic move to streamline the EU’s regulatory framework, reducing administrative burdens and boosting competitiveness at a critical time for sustainable growth. By aligning reform efforts with global trends and climate goals, the initiative aims to enhance investment, foster innovation, and position Europe as a leader in responsible markets. Its success could serve as a model for international standards, attracting foreign investment and shaping future global practices in green finance and sustainable development.
The European Commission’s proposal of the Omnibus Package represents a strategic effort to streamline a complex regulatory landscape that has grown increasingly challenging for businesses, consumers, and policymakers alike. This initiative is driven by the need to address mounting administrative burdens, enhance the efficiency of EU regulations, and foster a more competitive environment conducive to sustainable growth.
Several motivations underpin this move. Firstly, the EU faces ongoing global competition, which necessitates regulatory agility to ensure European companies can innovate and scale without being hindered by excessive legislative red tape. According to the European Commission’s own commitment, they aim to reduce administrative burdens by at least 25%, and up to 35% for SMEs, to improve the business environment (European Commission, “Better regulation”).
Secondly, the evolving climate and sustainability agendas, exemplified by the European Green Deal, demand a more coherent and simplified framework to mobilize investments, improve compliance, and meet ambitious climate targets for 2030 and beyond. The Green Deal’s overarching goals are outlined in the European Commission’s strategy document.
Current market conditions further amplify the need for reform. Businesses are grappling with fragmented rules that often overlap and evolve rapidly, leading to increased costs, reduced transparency, and diminished agility. The European Court of Auditors highlighted that existing regulatory fragmentation hampers the effectiveness of sustainability policies, calling for streamlined and coherent EU legislation (“Special report 10/2018: Better regulation, more Effective Regulation” ).
Regulatory complexity also impacts international attractiveness, potentially discouraging foreign investment and limiting the EU’s ability to lead in global clean-tech and sustainable finance sectors. The European Investment Bank highlights that regulatory uncertainty can inhibit green investments, which are crucial for achieving climate goals.
The Omnibus Package proposes revisions to four key pieces of ESG-related legislation: the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD), the Carbon Border Adjustment Mechanism (CBAM) and the EU Taxonomy Regulation.
In regard to the CSRD, the Omnibus Package proposes a higher employee threshold for companies in scope. Under the proposed revisions, companies with over 1,000 employees and either a turnover of more than €50 million or a balance sheet of more than €25 million still need to report. The employee threshold was previously 250 employees. The turnover threshold is also being increased for non-EU parent companies, from over € 150 million to over € 450 million. The ESRS data points are being simplified, no sector-specific standards will be developed, and only limited assurance will be required (as opposed to limited and reasonable). Furthermore, according to the Stop-the-Clock proposal, which has been adopted by the European Commission, there is a postponement to reporting for large non-listed organisations and listed small- and medium-sized enterprises (SMEs) by two years (2025 to 2027 and 2026 to 2028).
For the CSDDD, the Omnibus Package proposes delays of one and two year(s) to the transposition and compliance deadlines, respectively, to 26th July 2027 and to 26th July 2028. Furthermore, the due diligence obligation will be limited to direct business partners only, and the requirement to terminate business relationships when severe potential or actual adverse impacts are identified is being removed. Review cycles are being increased to five years, and the EU-level civil liability is being removed, leaving it up to national regimes.
For the EU Taxonomy, the Omnibus Package proposes focusing the KPIs on the very large companies only, with over 1,000 employees and more than €450 million in turnover. The disclosures are also being made simpler and lighter, with streamlined templates and a de minimis exemption, whereby no reporting will be required on activities that comprise less than 10% of turnover. Financial institutions will also be able to defer detailed KPIs to 31st December 2027.
These revisions simplify the reporting, align the provisions of different regulations and reduce the bureaucracy involved, thereby reducing the cost, time and effort required by businesses in scope to comply. The Stop-the-Clock proposal also gives businesses in scope more time to prepare their reporting. 80% fewer firms are estimated to be out of scope with these revisions, thereby removing an administrative burden and related costs for many SMEs. Furthermore, the limited assurance requirement makes it easier for businesses to comply and simpler for regulators to review. Enforcement will also remain national, which requires fewer resources and time.
Less coverage in data points and reduced overall transparency in reporting mean that the amount of ESG data available will significantly decrease, so users of this data (e.g. consumers, regulators, clients, partners, investors, media, public, etc.) will face a higher risk of blind spots and harder cross-sector comparability, particularly for high-impact sectors. The risks of scrutiny also increase as transparency decreases. The proposed revisions have also created uncertainties for businesses and a lack of clarity for the market. The requirement for limited assurance only will potentially impact the quality of the data being reported and reduce the need for relevant assurance services, negatively impacting service providers. Furthermore, companies out of scope may still have to comply with ESG procurement questionnaires from their value chain, so these companies will still need to allocate resources to comply and may be less prepared to do so, or able to score highly. With enforcement remaining only national, there is also the risk of patchwork liability and conflicting standards across the EU. Given that legislation in other regions tends to follow the EU, these revisions may also lead to a domino effect of revisions to similar pieces of legislation in other geographical areas e.g. Asia-Pacific, North America, etc., with more significant global market implications.
The adoption of the Omnibus Package positions the EU at a pivotal juncture, aligning its regulatory approach with broader international trends while signalling a clear shift towards more pragmatic and business-friendly policies. On an EU level, this initiative supports the continent’s strategic commitments under the European Green Deal and its sustainability objectives for 2030.
By reducing administrative burdens and enhancing regulatory clarity, the EU aims to incentivise sustainable investment, support innovation, and maintain its competitiveness on the global stage. The European Commission’s “Sustainable finance in the EU” report highlights the importance of regulatory clarity for mobilising private investments in sustainable finance. Externally, the implications are equally significant. As global markets increasingly prioritise sustainability and responsible business practices, the EU’s efforts to streamline and enhance its regulatory framework could serve as a model for other regions. The OECD’s recent publication on “Global Coordinated Approaches to Sustainable Finance” underscores that regulatory convergence plays a crucial role in fostering international investment flows and shared standards.
Countries and trading partners that align their policies with sustainable development goals may view the EU’s reforms as a benchmark to follow, thus shaping international standards in the years to come. The European Central Bank has also stressed that regulatory stability and transparency are vital for fostering sustainable finance at the global level.
Furthermore, a more streamlined EU framework can positively influence global supply chains. The World Economic Forum emphasizes that regions leading in clean technology and governance standards tend to attract more foreign direct investment (FDI) and drive innovation (World Economic Forum, “Why integrated and regenerative leadership is vital for the future of global value chains”).
The Omnibus Package does not change the EU’s legally binding 2030 target of reducing net greenhouse gas emissions by 55% compared to 1990, nor does it impact other key tools, such as the EU’s Emissions Trading System (ETS). The simplifications are intended to cut red tape and focus efforts on businesses with the biggest impact, in order to reduce costs and free up management capacity. The aim is to therefore to boost the competitiveness of all EU businesses, incentivise sustainable investment and support cross-sectoral innovation. The Package, therefore, remains in law.
However, the delays it introduces in reporting and the narrower scope of reporting and due diligence introduce execution and monitoring risks for successfully achieving the 2030 pathway. This is because the revisions send market signals that will make it harder to mobilise private finance and verify progress. The reduction in data being reported also means that the volume of decision-useful high-quality ESG data available will be significantly less, therefore providing weaker steering signals for boards, banks and supervisors. Furthermore, due to the reduced number of businesses in scope, fewer companies will be allocating capital, time and human resources to meeting the 2030 and Green Deal goals, at least in the short-term. There will also be negative impacts on risk assessment of climate threats and transition plans of businesses. So while the Omnibus Package maintains future ambitions, such as the EU’s 2030 goal, it complicates the roadmap to achieve that 2030 goal. But the goal is still attainable.
The Omnibus Package revisions also present a business opportunity for the mid-market, which is no longer in scope of these pieces of legislation. The management of ESG issues ceases to be a burdensome tick-box exercise for compliance for SMEs, but becomes a strategic imperative and business enabler. It is critical for market access and growth, as well as for the cost of capital and financing opportunities for companies.
According to the Global Trade Report published by Thomson Reuters for 2024, 81% of global respondents consider ESG criteria as important or very important when choosing suppliers[1]. The World Economic Forum noted that in 2024, according to a KPMG survey, 45% of M&A deals encountered a significant deal implication due to a material ESG due diligence finding, with more than half of these experiencing a ‘deal stopper’[2]. Unmanaged climate risks could also significantly impact global equity value and translate into a 27% loss, with the worst-performing firms losing up to 75% of their value, according to Cornell University[3].
The message is clear. If you remain in scope of these key pieces of ESG legislation, the road to compliance is now simpler and more straightforward for you. But if you’re no longer in scope, keep investing in climate-change transition plans; in high-quality ESG data for your strategies and reporting; and in supply chain due diligence on ESG, because the long-term competitiveness and resilience of your business depends on it.
[1] Thomson Reuters Institute, 2024 Global Trade Report, December 2024, https://www.thomsonreuters.com/en-us/posts/international-trade-and-supply-chain/supply-chain-resilience/
[2] World Economic Forum, Corporate Responsibility makes financial sense. Here’s why. March 2025, https://www.weforum.org/stories/2025/03/why-esg-is-now-a-financial-imperative/
[3] Cornell University, Quantifying firm-level risks from nature deterioration, April 2025, https://arxiv.org/abs/2501.14391
October 9, 2025
Overview of R&D Tax Relief in the Netherlands
The Netherlands has a strong innovation-friendly tax regime designed to support businesses conducting research and development activities. The two most important tax incentives for R&D in the Netherlands are the WBSO (Wet Bevordering Speur- en Ontwikkelingswerk) program and the Innovation Box. Together, they help companies lower the cost of R&D by reducing their tax burden, providing tax credits, and offering tax exemptions on income derived from innovative activities.
WBSO (R&D Tax Credit)
The WBSO program provides direct tax relief on R&D expenses, effectively lowering the effective labour costs associated with R&D activities. This is the most common R&D tax incentive in the Netherlands and is available to both small and large companies involved in technological or scientific research.