Radar archive — January 2026
IFSCA loosens fund-manager rules for GIFT City vehicles
The IFSCA (Fund Management) (Amendment) Regulations, 2026, notified on 27 January 2026, relax key-managerial-personnel experience requirements, give fund management entities more time and a one-time extension window to reach minimum corpus, and lengthen the custodian-appointment transition to 24 months. The amendments also refine scheme operation, winding-up and investor-safeguard provisions for funds domiciled in the GIFT City IFSC.
Implications for capital — The revisions ease the staffing and fundraising constraints on launching and operating regulated funds in India's offshore financial centre.
Source: International Financial Services Centres Authority (IFSCA)
FINMA sets custody standards for crypto-based assets
FINMA published guidance explaining how it assesses the risks of holding crypto-based assets such as Bitcoin and Ether, setting expectations around segregation of client assets, bankruptcy protection, technical infrastructure and the use of third-party (including foreign) custodians. Supervised institutions remain accountable when custody is outsourced, and must ensure clients' assets are segregable in an insolvency.
Implications for capital — It clarifies the conditions under which Swiss-supervised institutions may safekeep digital assets, bearing on where and how custodied crypto wealth is legally protected in a custodian failure.
Source: FINMA
Montevideo pulls public-savings schemes into the central bank's net
The same 2025-2029 Budget Law expanded the Banco Central del Uruguay's regulatory perimeter, empowering the Superintendencia de Servicios Financieros to supervise persons and asset pools that raise money from the public for financial operations without issuing securities or acting as intermediaries. The reform captures real-asset investment schemes — in livestock, forestry and real estate — that had previously fallen outside oversight, following the collapse of several livestock ('fondos ganaderos') vehicles.
Implications for capital — Operators soliciting public savings for real-asset schemes now fall within BCU supervision, information and advertising controls, changing how such capital can be raised in Uruguay.
Uruguay recasts its tax holiday for new residents
Law No. 20.446, the 2025-2029 National Budget promulgated on 16 December 2025 and published on 8 January 2026, reshaped the regime for new tax residents from 1 January 2026. It broadened IRPF on foreign-source income to include real-estate returns and capital gains; for those acquiring residency from 2026 it offers exemption (via IRNR) in the year of arrival plus ten years, then a reduced 6% IRPF rate for a further five years, while residency routes not based on the 183-day rule now require qualifying investment in Uruguay.
Implications for capital — The reform lengthens the exemption period but ties it to a wider foreign-income base and, for investment-based residency, to capital commitments inside Uruguay.
OECD confirms Bahrain's 15% top-up tax as a qualified regime
The OECD's Central Record of Legislation with Transitional Qualified Status, declassified by the G20/OECD Inclusive Framework on 5 January 2026, lists Bahrain's Decree-Law No. 11 of 2024 as a Qualified Domestic Minimum Top-up Tax with a qualifying QDMTT Safe Harbour, effective 1 January 2025. The regime imposes a 15% minimum effective tax on Bahraini entities of multinational groups with consolidated revenue of at least EUR 750 million in two of the four preceding years.
Implications for capital — In-scope groups with Bahraini entities face a 15% effective-tax floor locally, while the safe-harbour status limits other jurisdictions from levying additional top-up tax on those Bahraini profits.
Inclusive Framework agrees 'side-by-side' global minimum tax package
On 5 January 2026 the 147-member OECD/G20 Inclusive Framework agreed key elements of a side-by-side arrangement for the global minimum tax, adding simplification measures, a substance-based incentive safe harbour and new safe harbours for groups parented in eligible jurisdictions that meet minimum-taxation requirements. Qualified domestic minimum top-up taxes remain the primary mechanism.
Implications for capital — Reshapes how large multinational and fund structures calculate and report top-up tax and how domestic minimum-tax regimes interact across jurisdictions.
Source: OECD
Sweden makes the first SEK 300,000 on ISK and endowment accounts tax-free
From 1 January 2026 the tax-free base for investment savings accounts (ISK) and capital insurance (kapitalförsäkring) rises to SEK 300,000, doubling the SEK 150,000 level introduced during 2025. Holdings above the threshold are taxed on a standardised return (schablonintäkt) set at 3.55% for 2026, giving an effective annual rate of roughly 1.065%.
Implications for capital — The exemption lowers the flat annual charge on Sweden's main personal investment wrappers, changing the after-tax comparison between ISK/KF and directly held securities.
Source: Skatteverket
Italy lifts its new-resident flat tax to €300,000
Under the 2026 Budget Law, the substitute tax on foreign-source income for individuals transferring their tax residence to Italy rises to €300,000 a year, with €50,000 per additional family member. The increase applies to those becoming Italian tax resident from 1 January 2026; those already enrolled keep the prior €200,000 rate for the remainder of their term.
Implications for capital — The cost of Italy's non-dom-style regime doubles for incoming principals, raising the level of foreign income at which relocation to Italy is fiscally neutral.
Source: Agenzia delle Entrate
Belgium introduces a 10% tax on capital gains from financial assets
From 1 January 2026 Belgium taxes realised capital gains on financial assets — shares, bonds, funds, derivatives, certain insurance products and crypto-assets — at 10%, with an annual exemption of the first €10,000 (indexed). A reduced progressive scale applies to holders of a substantial (20%+) interest. The FOD Financiën has issued circular 2026/C/74 on the calculation.
Implications for capital — For the first time a broad category of individual investment gains falls within scope, materially changing the after-tax return on Belgian-resident private and family portfolios.
Source: FPS Finance (FOD Financiën)