Radar archive — June 2025
Higher entry and interim tax on Austrian private foundations
The Budgetbegleitgesetz 2025 raised the foundation entry tax (Stiftungseingangssteuer) levied on gratuitous contributions into a domestic private foundation from 2.5 to 3.5 percent, with the real-estate equivalent charge moving in step. The interim tax (Zwischensteuer) on private foundations rises from 23 to 27.5 percent, both taking effect from 2026.
Implications for capital — Funding an Austrian Privatstiftung and retaining income within it becomes more costly, changing the arithmetic of a long-standing wealth-holding vehicle for families.
Austria closes the real-estate share-deal loophole
The Budgetbegleitgesetz 2025, published in the Federal Law Gazette on 30 June 2025, rewrote the real-estate transfer tax (Grunderwerbsteuer) treatment of share deals. Transfers reaching a 75 percent shareholding within seven years now trigger the tax (down from 95 percent over five years), all property-holding companies are captured regardless of legal form, and dealings in an Immobiliengesellschaft are taxed at 3.5 percent of the property's fair value rather than 0.5 percent of the assessed value.
Implications for capital — Acquiring Austrian real estate through corporate wrappers no longer reliably avoids transfer tax, and the charge is now assessed on market value for property companies. The rules apply to transactions from 1 July 2025.
QFC brings ISSB-aligned sustainability reporting into force
The QFC Regulatory Authority issued its GENE Corporate Sustainability Reporting and Minor and Technical Amendments Rules 2025, requiring disclosures aligned with ISSB standards IFRS S1 and IFRS S2. The rules apply to all Category A firms — larger banks and insurers — plus other firms designated by the Authority, with the core reporting schedule commencing 1 January 2026; branches and subsidiaries may rely on group-level reports.
Implications for capital — Larger QFC-based financial entities now carry standardised climate and sustainability disclosure obligations, adding a reporting layer relevant to institutions and groups operating capital through the centre.
Source: QFC Regulatory Authority (QFCRA)
ESA keeps Norway's exit tax on unrealised share gains under EEA scrutiny
In Decision 094/25/COL of 25 June 2025 the EFTA Surveillance Authority closed one complaint (Case 93011) against Norway's exit tax on individuals — but only to consolidate the issue into a designated lead case (No 93706) rather than to dismiss it. The complaint argued that taxing unrealised share gains on emigration, with no downward adjustment if the shares later fall in value, breaches the EEA rules on free movement of persons, establishment and capital (Articles 28, 31 and 40).
Implications for capital — Norway's exit-tax treatment of departing shareholders remains the subject of an active ESA examination under the EEA Agreement.
Source: EFTA Surveillance Authority
Oman enacts the GCC's first personal income tax
Royal Decree No. 56/2025 promulgated Oman's Personal Income Tax Law, the first such regime in the Gulf, taking effect on 1 January 2028. A 5% tax applies to natural persons whose annual gross income exceeds OMR 42,000 (about USD 109,000); the Oman Tax Authority indicates roughly 99% of the population falls below the threshold, with deductions for education, healthcare, housing, inheritance, zakat and donations.
Implications for capital — From 2028 Oman becomes the first GCC state to tax individual income, a consideration for internationally mobile high earners assessing Gulf residence.
Source: Oman Tax Authority
Singapore extends beneficial-ownership transparency to central registers
From 16 June 2025 the Companies and Limited Liability Partnerships (Miscellaneous Amendments) Act requires all new companies and LLPs to maintain a Register of Controllers from incorporation and mandates annual verification of controller information. ACRA now maintains central registers of nominee directors and nominee shareholders, with existing entities required to file by 31 December 2025. The reforms were framed as reinforcing Singapore's anti-money-laundering regime.
Implications for capital — Nominee and controller information on Singapore holding structures moves from private registers into ACRA-held central records, reducing the opacity of layered ownership. Ongoing verification converts transparency into a recurring compliance duty for corporate and LLP vehicles.
Source: Accounting and Corporate Regulatory Authority (ACRA)
MAS closes the door on offshore-only digital token providers
MAS confirmed that from 30 June 2025, providers of digital-payment-token and capital-markets-token services that serve only customers outside Singapore must be licensed under the Financial Services and Markets Act 2022. MAS set the licensing bar deliberately high and signalled it will generally not grant such licences, meaning affected firms must cease the activity. Providers already serving Singapore customers are unaffected.
Implications for capital — Digital-asset operators using a Singapore base solely to serve overseas clients lose that option, redirecting where such crypto-service capital and infrastructure can sit. The measure narrows Singapore's perimeter to substantively supervised, locally connected activity.