USA Update: FIRE System Retires in November : 3 Deadlines International Sellers Must Know

USA Update: FIRE System Retires in November : 3 Deadlines International Sellers Must Know

TITLE: FIRE to IRIS Transition: Final Deadlines Every International Seller Must Know

The IRS is retiring the FIRE system in November 2026. If you file US information returns, you must prepare for the move to IRIS before the 2027 filing season.

This change matters to UK sellers in London, Manchester and Birmingham, EU ecommerce businesses, foreign-owned US LLCs and international companies selling into the US through Amazon FBA, Shopify and other marketplaces.

The IRS announced the transition in News Release IR-2026-99, published on 24 August 2026.

Act before these three FIRE deadlines

The transition includes three important dates. Missing the final date could prevent you from filing through FIRE.

1. Test your information returns by 1 November 2026

1 November 2026 is the final day to file test information returns through the FIRE Trading Partner Test System.

Use this deadline to:

  • Test your filing software.
  • Check your file format.
  • Validate payer and recipient data.
  • Identify rejected records.
  • Confirm that your third-party filer can transmit successfully.

Testing early gives you time to correct technical errors before the production system closes. Do not wait until the final filing deadline to discover that your data file is invalid.

2. Update your FIRE application by 9 November 2026

9 November 2026 is the last day to make changes to Information Returns Applications for Transmitter Control Codes, commonly called TCCs.

Review your existing FIRE application now. Check:

  • Responsible officials.
  • Authorised contacts.
  • Business details.
  • Filing responsibilities.
  • Third-party transmitter arrangements.
  • The information returns your business expects to submit.

After this date, changes to your FIRE application will no longer be available in the same way. Keeping your records accurate helps prevent access and authorisation problems during the transition.

3. File through FIRE by 19 November 2026

19 November 2026 at 3 p.m. Eastern Time is the final deadline for filing information returns through FIRE.

That is 8 p.m. UK time on 19 November 2026.

This is the most important deadline for international sellers. If you have outstanding FIRE filings, corrections or other submissions, plan to complete them well before the final afternoon.

After the November maintenance window, FIRE will no longer accept information returns. From 1 January 2027, IRIS will be the sole IRS electronic filing system for information returns, including current-year, prior-year and correction filings.

Move from FIRE to IRIS before the 2027 filing season

IRIS, or the Information Returns Intake System, is the IRS replacement for FIRE. The IRS has provided two filing channels.

Use the free IRIS Taxpayer Portal for smaller filing volumes

The IRIS Taxpayer Portal is a free, web-based filing system.

You can use it to:

  • Enter information manually.
  • Upload data using a CSV file.
  • File up to 100 returns per filing.
  • Download payee copies.
  • Maintain records of completed submissions.

The portal may suit a smaller business filing a limited number of 1099 forms. It is also useful if you do not have a compatible third-party filing system.

Prepare your data carefully. A CSV upload does not remove your responsibility to provide accurate taxpayer identification numbers, payment information and recipient details.

Use IRIS Application to Application for higher volumes

IRIS Application to Application, or A2A, is designed for high-volume filers using third-party software or their own systems.

This channel may be more suitable if you:

  • File hundreds or thousands of information returns.
  • Use accounting, payroll or compliance software.
  • Need an automated system-to-system process.
  • Already rely on a third-party transmitter.
  • Want to reduce manual data entry.

Ask your software provider whether it supports IRIS A2A. Do this early because testing, authorisation and data mapping may take time.

Understand the IRIS TCC requirement

Your existing FIRE TCC will not automatically work with IRIS.

You must apply for an IRIS TCC through the IRS. FIRE TCCs and IRIS TCCs are system-specific. They are not interchangeable.

This is a key operational point for any business that currently uses FIRE for 1099 filing or other US information returns. Applying for the correct IRIS TCC early will reduce the risk of a last-minute filing failure.

Keep evidence of:

  • Your IRIS application.
  • TCC approval.
  • User permissions.
  • Software authorisation.
  • Test submissions.
  • Rejected and corrected records.

These records support a clear compliance trail if you need to investigate a filing issue later.

Check the foreign filer process

International sellers need to understand which IRS process applies to them.

A non-US filer without an SSN or ITIN may need to use the Foreign Filer TCC Registration system for the applicable electronic filing process. The registration process includes:

  1. Signing in through Login.gov or ID.me.
  2. Creating or accessing a Foreign Filer account.
  3. Obtaining a Foreign Filer ID.
  4. Obtaining a TCC GIIN.
  5. Enrolling in IDES where required.
  6. Allowing approximately three to six weeks for the process.

The Foreign Filer ID is not the same as a TCC. The TCC GIIN is also a specific identifier used for the relevant registration and enrolment process.

Do not assume that a Foreign Filer TCC, FIRE TCC, IRIS TCC and IDES credentials can be used interchangeably. They cannot. Confirm which channel applies to your filing obligation before submitting an application.

If your foreign business has an authorised user with a US SSN or ITIN, the IRS may direct you to apply for an IRIS TCC through the standard IRIS process instead. Review the latest IRS foreign filer guidance and IRIS TCC instructions before proceeding.

See how the change affects international sellers

Example 1: A UK Amazon seller filing US forms

A UK Limited Company based in London sells products to US customers through Amazon FBA. Its US reporting obligations may include 1099 forms or Form 1042-S, depending on the payments, recipients and structure involved.

The business should:

  • Review which US information returns it files.
  • Confirm whether it currently uses FIRE or a third-party transmitter.
  • Test its files before 1 November.
  • Review its FIRE application before 9 November.
  • Submit any required FIRE returns before 19 November at 3 p.m. ET.
  • Apply for the correct IRIS TCC or follow the applicable foreign filer process.
  • Confirm that Amazon, its software provider or its filing agent has a 2027 IRIS workflow.

The same approach applies to sellers operating from Manchester, Birmingham or elsewhere in the UK.

Example 2: A foreign-owned US LLC using a third-party filer

A foreign-owned US LLC receives marketplace income and uses an external provider to prepare and transmit its information returns. The LLC may not interact with FIRE directly, but it remains responsible for the accuracy and timely submission of its filings.

The LLC should:

  • Verify that its third-party filer is registered for IRIS and has a valid IRIS TCC.
  • Ask whether the filer will use the IRIS Taxpayer Portal or A2A for the 2027 season.
  • Obtain confirmation in writing that test files have been accepted in the IRIS environment.
  • Review the filer’s timeline for completing the transition before November 2026.
  • Check that the LLC’s own records—such as recipient name, address and taxpayer identification number—are up to date.
  • Plan for a possible gap in filing capacity if the third-party filer is slow to migrate.

This example also applies to foreign-owned LLCs that do not have direct IRS filing accounts and rely entirely on external compliance partners.

Example 3: An EU business with Form 1042-S obligations

An EU ecommerce business with US-source payments may need to file Form 1042-S to report income paid to foreign persons. If it currently uses FIRE for this purpose, the transition to IRIS requires a fresh look at its entire filing setup.

The business should:

  • Determine whether it files as a foreign filer or through a US-based agent.
  • Secure the correct Foreign Filer TCC or IRIS TCC well ahead of the transition date.
  • Complete any IDES enrolment if required for its specific filing type.
  • Test its 1042-S data files in the new system before the end of the test window.
  • Allow the three to six weeks processing time for foreign filer registration.
  • Coordinate with any withholding agents to ensure beneficiary data matches.

Missing the transition deadlines could delay 1042-S filings and create compliance exposure for the business.

Prepare your transition plan now

The FIRE to IRIS transition is not a routine software update. It is a system-wide change that affects how information returns are tested, transmitted and tracked.

Build your plan around these steps:

Audit your current filing method

Identify every form your business files through FIRE. This may include Forms 1099-NEC, 1099-MISC, 1099-K, 1042-S or others. Verify whether you file directly or through a third party.

Confirm your TCC status

Check whether your existing TCC is a FIRE TCC or an IRIS TCC. If you have not applied for an IRIS TCC, start the process immediately. If you are a foreign filer, confirm whether the Foreign Filer TCC Registration system applies to you.

Contact your software provider

Ask your software vendor or filing agent whether they support IRIS A2A. Confirm their testing schedule and request evidence of successful IRIS test transmissions.

Set internal milestones

Work backwards from 19 November 2026. Set internal deadlines for completing test files, updating applications and finalising submissions. Do not rely on the IRS deadlines as your only reference points.

Document everything

Keep copies of all applications, approvals, test submissions, error reports and correction records. This documentation will be useful if the IRS contacts you about a filing issue during the transition period.

Act before the November 2026 cut-off

The FIRE system is closing. The IRS will not extend the 19 November 2026 deadline for individual filers or business filers, regardless of jurisdiction.

International sellers and foreign-owned entities face additional complexity because of the Foreign Filer TCC Registration process and the three to six week processing time. Starting the application process in mid-2026 gives you a realistic buffer.

If you file US information returns of any type, your next step is clear: test early, update your applications before 9 November, and complete all FIRE submissions before 19 November at 3 p.m. Eastern Time. Then move your entire workflow to IRIS before the 2027 filing season begins.

Digital Business Growth & Strategy Weekly: The Q4 2026 Growth Playbook for Scaling SMEs Ready to Expand Globally

Digital Business Growth & Strategy Weekly: The Q4 2026 Growth Playbook for Scaling SMEs Ready to Expand Globally

TITLE: The Q4 Ecommerce Finance Playbook: Cash, Compliance, and 2027 Planning

Q4 is not just your final sales push. It is your planning window for a stronger, more controlled 2027.

You can use the final quarter to protect cash, improve contribution margins, prepare for peak-season demand and build the compliance systems required for global expansion.

This playbook gives you a practical framework for doing exactly that.

Start with the numbers that control growth

Revenue growth can look impressive while cash becomes tighter. That happens when stock, advertising, payroll, tax payments and international expansion costs grow faster than customer collections.

Build a Q4 dashboard that separates:

  • Revenue by country, channel and product.
  • Variable costs, including fulfilment, payment fees, returns and advertising.
  • Contribution margin by product and market.
  • Fixed operating costs.
  • VAT, GST and Sales Tax collected.
  • Tax payments and filing dates.
  • Cash available after tax and supplier commitments.

Your contribution margin shows what remains after the costs directly linked to each sale.

For example, if a product sells for £100 and its direct product, fulfilment, payment and advertising costs total £65, the contribution margin is £35, or 35%.

Do not treat VAT or Sales Tax collected from customers as revenue. Ring-fence it as a future payment obligation. Doing this prevents tax liabilities from being accidentally spent on stock or marketing.

Use this contribution-margin checklist

  • Calculate margin by product, not just by business.
  • Separate direct website sales from marketplace sales.
  • Include refunds, discounts and chargebacks.
  • Include currency conversion costs.
  • Compare margin before and after VAT or Sales Tax.
  • Pause products that grow revenue but weaken cash generation.

A global expansion decision should improve your after-tax contribution margin, not merely increase order volume.

For more guidance on managing international cash movements, review our cross-border currency management guide.

Build three Q4 scenarios before committing cash

Do not rely on one forecast. Build at least three.

Scenario one: Base case

Assume your current markets continue with moderate growth. Include normal seasonal demand, existing staff and current supplier terms.

Scenario two: Growth case

Assume stronger US peak-season sales, additional advertising and stock investment. Add potential registrations and filing costs in new jurisdictions.

Scenario three: Stress case

Assume slower customer payments, higher returns, weaker exchange rates and delayed inventory. This scenario shows whether you can survive growth that arrives later than expected.

Track these figures every month:

  • Closing cash balance.
  • Stock commitments.
  • Payroll and supplier payments.
  • VAT, GST and Sales Tax outflows.
  • Advertising spend.
  • Contribution margin by market.
  • Foreign exchange exposure.
  • Minimum cash reserve.

Set decision triggers in advance. For example, you might delay a new warehouse if the stress case takes cash below three months of fixed costs.

This approach helps you scale deliberately rather than allowing Q4 demand to dictate every decision.

Prepare for the US peak season without losing control

The US can be a major growth market for ecommerce brands, SaaS businesses and digital service companies. It can also create several separate compliance obligations.

Start by mapping:

  • Where your customers are located.
  • Whether you sell goods, digital products or services.
  • Whether inventory is held in the US.
  • Whether a marketplace collects tax on your behalf.
  • Whether you sell directly through your own website.
  • Whether you use US staff, contractors, warehouses or fulfilment partners.

Monitor state Sales Tax nexus

California’s official guidance states that remote retailers generally need to register and collect California use tax when combined sales of tangible personal property delivered into California exceed $500,000 in the preceding or current calendar year. Physical presence, including inventory or offices, can create obligations independently. Review the California Department of Tax and Fee Administration guidance.

New York uses a different measurement. A remote seller with no physical presence may meet the economic nexus presumption when it has more than $500,000 of New York sales and 100 or more sales of tangible personal property delivered into the state during the immediately preceding four sales tax quarters. Both conditions matter. Read the New York Department of Taxation and Finance advisory opinion.

Create a state-by-state tracker showing:

  • Rolling sales.
  • Transaction counts.
  • Marketplace and direct sales.
  • Inventory locations.
  • Registration status.
  • Return frequency.
  • Tax collected and paid.

Do not assume that a marketplace collecting tax removes every reporting responsibility. Keep complete records for all channels.

Clarify the importer of record before shipping

If you send physical goods internationally, decide who acts as the importer of record before you increase Q4 volume.

The importer of record is generally responsible for ensuring that the import is correctly documented and that applicable duties, import taxes and customs requirements are dealt with. Using a customs broker can simplify the process, but it does not automatically remove the need to understand who carries the underlying responsibility.

Confirm:

  • Product classification and commodity codes.
  • Customs value.
  • Country of origin.
  • Import permits or product requirements.
  • Who pays import VAT and duties.
  • Who owns goods during transit.
  • Whether the customer, seller, marketplace or fulfilment provider is importer of record.
  • How customs data will be retained for your accounts.

Write the arrangement into your fulfilment and marketplace agreements. This avoids unexpected landed costs, delivery delays and disputes during peak season.

Protect UK VAT headroom before year-end

The UK VAT registration threshold is more than £90,000 of taxable turnover over the relevant rolling 12-month period. HMRC also lists an optional deregistration threshold of less than £88,000. Check the latest HMRC VAT thresholds and VAT registration rules.

Do not monitor only your accounting-year revenue. Review taxable turnover monthly on a rolling basis.

Your Q4 checklist should include:

  • Reconcile all sales channels.
  • Include taxable sales that may not yet have been paid out.
  • Exclude exempt income correctly.
  • Review sales made through marketplaces.
  • Forecast whether December activity could push you over the threshold.
  • Prepare systems for VAT invoices and Making Tax Digital-compatible records.
  • Model the effect of VAT on consumer pricing and contribution margin.

If you are approaching the threshold, act early. Registering on time protects you from backdated liability and keeps your Q4 planning on track.

USA Tax Update: IRS Online Tools, Oct 15 Filing Deadline & Kentucky Nexus Change , What International Sellers Must Know

Plan for the key deadlines: October and September dates you cannot ignore

International sellers face four important USA compliance points this September: improved IRS online tools, the 15 October 2026 filing deadline, Kentucky’s removal of its 200-transaction nexus test, and stricter U.S. Customs and Border Protection checks for Importers of Record.

Use this checklist to protect your filings, sales tax registrations, inventory movements and cash flow.

Act now: the four deadlines and changes to track

Here is the short version:

  • 15 October 2026: Final extended filing deadline for eligible 2025 federal return extension filers.
  • 15 October 2026: Deadline for qualifying foreign-owned U.S. LLCs to file Form 5472 with a pro forma Form 1120 when Form 7004 was filed on time.
  • 1 August 2026: Kentucky removed its 200-transaction economic nexus test.
  • 18 September 2026: CBP may void Importer of Record numbers linked to inaccurate or incomplete Form 5106 data.

Do not treat these as isolated administrative updates. Each one affects how you file, pay, register or move goods in the United States.

Use IRS online tools to control your compliance records

The IRS has encouraged taxpayers, businesses and tax professionals to use its online services in IR-2026-102.

For international businesses, these tools can reduce delays and give you a clearer record of your federal tax position.

Open and review your Business Tax Account

Eligible businesses can use the IRS Business Tax Account to access certain federal tax information. Available features depend on your entity type and user role.

You may be able to:

  • View business information held by the IRS.
  • Check account balances and payment history.
  • Make federal tax deposits and balance-due payments.
  • Access tax transcripts.
  • Obtain an EIN verification letter.
  • View tax compliance reports.
  • Access certain notices and letters.
  • Manage authorised users.

The account is available to several business structures, including partnerships, S corporations, C corporations and other eligible organisations. Access may be limited depending on your role.

Keep your user permissions controlled. This reduces the risk of missed notices or unauthorised account changes.

Use Tax Pro Account for authorisations

Tax professionals can use the IRS Tax Pro Account to manage certain Power of Attorney and Tax Information Authorisation requests.

Where available, clients may review, approve and electronically sign authorisation requests through their own IRS online account. This can speed up access to information needed for filing and compliance work.

Other useful IRS tools include:

Use only IRS.gov when signing in. The IRS does not initiate contact by email, text message or social media to request personal or financial information. Do not click suspicious links or share your account credentials.

File by 15 October: an extension does not extend payment

The IRS has reminded 2025 federal return extension filers to submit their returns as soon as possible rather than waiting until 15 October 2026.

The central rule is simple:

An extension gives you more time to file. It does not give you more time to pay.

If tax was due by the original deadline, interest and applicable penalties may continue to apply when payment is late. Review your estimated liability now and arrange payment through the appropriate IRS channel.

Eligible individual taxpayers may also use IRS Free File through 15 October 2026 where their adjusted gross income is $89,000 or less. Free File Fillable Forms may be available to taxpayers above that threshold.

Pay particular attention to foreign-owned U.S. LLC filings

A foreign-owned U.S. LLC may have a Form 5472 reporting obligation. This commonly applies where reportable transactions take place between the LLC and a foreign or domestic related party.

For a calendar-year foreign-owned U.S. LLC:

  1. The 2025 filing package was generally due on 15 April 2026.
  2. A timely Form 7004 can extend the filing deadline.
  3. The extended deadline is 15 October 2026.
  4. The filing package generally includes Form 5472 and a pro forma Form 1120.

If your LLC has a Form 5472 obligation and Form 7004 was filed by the original deadline, complete the package before 15 October.

The IRS states that late filing of Form 5472 can result in a $25,000 penalty per return. The penalty may be reduced to $5,000 where reasonable cause applies, but you should not rely on penalty relief. Build the filing into your compliance timetable.

Review the official IRS Form 5472 guidance and confirm the exact obligation for your entity.

Remove Kentucky’s obsolete transaction trigger

Kentucky has removed its 200-transaction economic nexus test for remote retailers and marketplace providers.

The change took effect on 1 August 2026 under House Bill 757. Sellers should now focus on the $100,000 gross sales threshold for Kentucky sales rather than using 200 transactions as a separate economic nexus trigger.

Apply the new Kentucky review process

Complete these steps:

  1. Recalculate Kentucky sales. Review current-year and prior-year gross sales into Kentucky.
  2. Remove the obsolete transaction trigger. Do not register solely because you exceeded 200 Kentucky transactions.
  3. Check the $100,000 threshold. Determine whether your Kentucky gross sales exceed the applicable threshold.
  4. Review marketplace data. Include the relevant sales information from platforms and marketplace providers.
  5. Reassess existing registrations. If you registered only because of the old transaction count, confirm whether another obligation still applies.

The change does not mean every seller can cancel a Kentucky registration automatically. Inventory, employees, other physical presence and specific marketplace obligations may require a separate review.

Read Kentucky’s official guidance for full details.

Check your Importer of Record status before 18 September

U.S. Customs and Border Protection has been reviewing Importer of Record numbers. If your Form 5106 data is inaccurate or incomplete, CBP may void your number on 18 September 2026.

An Importer of Record number is essential for clearing goods through U.S. customs. A voided number can delay shipments, disrupt your supply chain and create cash flow problems.

Verify that your legal name, address, entity type and tax identification details on file with CBP are current and match your official records.

If you use a customs broker, confirm that your records match their filings. Discrepancies between your data and your broker’s data are a common cause of compliance issues.

Act before 18 September to avoid unnecessary disruption.

Build a September review checklist

Use this simple checklist to stay on track:

  • Confirm your IRS filing status and any outstanding balance.
  • File any extended 2025 federal returns before 15 October 2026.
  • Complete Form 5472 and pro forma Form 1120 for qualifying foreign-owned LLCs.
  • Review Kentucky sales against the $100,000 threshold.
  • Verify your Importer of Record data with CBP before 18 September 2026.
  • Update your internal compliance calendar with all relevant dates.

These actions are straightforward but time-sensitive. Taking them now protects your U.S. market access and avoids costly penalties.

Daily Australia Tax Update: 30 August 2026 : ATO Flags 6,000 Property Sales With Unpaid CGT, SMSF Borrowing Ban in Force & Tax Reform Bill 2 Awaits Assent

TITLE: ATO Property CGT Crackdown, SMSF Borrowing Changes & Tax Reform No. 2: Daily Update

Australia’s tax compliance environment is becoming more data-driven. The ATO is comparing tax returns with property, banking and government records to identify missing income and capital gains.

This daily update covers the ATO’s investment property CGT crackdown, new SMSF borrowing restrictions, the latest Tax Reform No. 2 status, cyber security controls, lost superannuation and expanded real property transfer reporting.

Important legislative update: The Treasury Laws Amendment (Tax Reform No. 2) Bill 2026 passed the Senate on 19 August 2026 and, based on the latest official reporting, awaits Royal Assent. Businesses should monitor the enactment date and rely on current ATO guidance once the law commences.

Review investment property sales before the ATO contacts you

The ATO is investigating approximately 6,000 investment property sales made across Australia between 1 July 2020 and 30 June 2025.

The investigation followed data matching between tax returns and state and territory property records. As reported by the Australian Financial Review, the potential unpaid tax across the identified transactions could be approximately $66 million.

The ATO can receive property information from:

  • State and territory revenue offices.
  • Land titles offices.
  • Banks and lenders.
  • Property managers.
  • Rental bond authorities.
  • Settlement and conveyancing records.

The ATO then compares this information with income tax returns. A discrepancy may arise where a taxpayer sold an investment property but did not report the capital gain or loss.

You must generally report a capital gain or capital loss in the income year when the contract of sale is entered into, rather than waiting until settlement. A capital gain may still need to be reported even where an exemption or concession reduces the final tax payable.

The ATO’s guidance on CGT when selling a rental property explains the records you should retain and the main calculation stages.

Complete this property CGT checklist

If you sold an investment property in Sydney, Melbourne, Brisbane, Perth, Canberra or elsewhere in Australia during the review period:

  1. Identify the contract date.
    This confirms the income year in which the CGT event should have been reported.
  2. Locate the original purchase records.
    Keep the contract, settlement statement, stamp duty records and eligible acquisition costs.
  3. Gather improvement and ownership records.
    Renovation invoices, legal costs and other eligible cost-base items may affect the calculation.
  4. Review rental history.
    Confirm when the property was first rented, whether it was ever your main residence and whether the property had mixed use.
  5. Check the tax return.
    Confirm that the sale, capital gain or capital loss was included in the correct year.
  6. Respond promptly to an ATO letter.
    The reported campaign gives affected taxpayers an opportunity to review their position and respond, with letters reportedly requesting action by 31 October 2026.

Do not ignore a notice. If the ATO issues a default assessment, it may calculate the tax using its own information. The taxpayer may then need to prove both that the ATO’s figure is wrong and what the correct figure should be. Penalties and interest may also apply.

If you identify an error before the ATO takes formal action, consider correcting the return through a voluntary disclosure. Penalties are generally lower where taxpayers come forward promptly and provide complete information, although interest may still apply.

Apply the new SMSF borrowing rules from 10 August

New restrictions now apply to limited recourse borrowing arrangements, commonly known as LRBAs, used by self-managed super funds.

For a new LRBA entered into from 10 August 2026, the real property generally needs to qualify as business real property. This means ordinary residential property held as a private rental investment can no longer generally be purchased through a new SMSF LRBA.

Business real property usually involves land and buildings used wholly and exclusively in one or more businesses. Examples may include:

  • A warehouse used by a trading business.
  • A commercial office leased to an operating business.
  • A retail premises used for genuine business activity.
  • Certain primary production land, subject to specific conditions.

The restriction is not a total ban on all SMSF borrowing. SMSFs may still use LRBAs for other permitted assets, subject to the superannuation rules.

Existing arrangements generally continue under transitional rules. This may include an existing residential property LRBA entered into before 10 August 2026, as well as certain purchases supported by a binding contract exchanged before that date.

Review your position if your SMSF has:

  • An existing residential property LRBA.
  • A proposed property purchase.
  • A contract exchanged before 10 August 2026.
  • A refinancing arrangement.
  • A commercial property acquisition under consideration.
  • A related-party loan or holding trust structure.

Keep the loan documents, contract, settlement records, trust documents and evidence of property use together. These records will help establish whether the arrangement falls within the transitional rules.

Read the ATO’s guidance on changes to limited recourse borrowing arrangements.

The government is also progressing a proposed SMSF reform package. The proposals include giving the ATO greater power to prevent rollovers into new SMSFs where fraud or misconduct is being investigated, requiring trustee education before SMSF registration and introducing uniquely identifiable SMSF bank accounts. Treat these proposals separately from the LRBA restrictions already in force.

Use the new Tax Reform No. 2 measures in your 2025–26 planning

The Treasury Laws Amendment (Tax Reform No. 2) Bill 2026 passed the Senate on 19 August 2026 and, based on the latest official reporting, awaits Royal Assent.

Two measures are particularly relevant to Australian small and growing businesses once the Bill is enacted.

$20,000 instant asset write-off

Once enacted, the legislation will make the $20,000 instant asset write-off permanent from 1 July 2026 for eligible small businesses.

The measure is expected to apply to businesses with aggregated annual turnover below $10 million. Eligible assets costing less than $20,000 may be immediately deducted on a per-asset basis. Assets costing $20,000 or more may generally be placed into the simplified depreciation pool.

Maintain clear records for every asset. Keep the purchase invoice, date first used or installed, business-use percentage and payment evidence. This will help you prepare for the measure taking effect and make year-end accounts easier to complete.

Two-year

UAE Business Setup & Strategy Spotlight: Late August 2026 Edition for Digital and Global Businesses

UAE Business Setup & Strategy Spotlight: Late August 2026 Edition for Digital and Global Businesses

TITLE: Key UAE Tax and Compliance Deadlines for Digital Businesses in Late August

File your 2025 Corporate Tax return by 30 September 2026

Businesses with a 31 December 2025 financial year end must submit their Corporate Tax return and settle any tax due by 30 September 2026.

You must file through EmaraTax, even if you expect to claim Small Business Relief.

Do not assume that relief removes your compliance obligations. The FTA confirmed on 3 August 2026 that eligible businesses must still:

  • Register for Corporate Tax where required.
  • Submit a simplified Corporate Tax return.
  • Make the Small Business Relief election inside the return.
  • Maintain appropriate accounting records.
  • Pay any tax due by the statutory deadline.

The general rule is that the return and payment are due within nine months after the end of the relevant tax period. If your year end is different, calculate your deadline from that year-end date.

Elect Small Business Relief correctly

Ministerial Decision No. 131 of 2026 extends Small Business Relief to tax periods ending on or before 31 December 2029.

The AED 3 million revenue threshold remains unchanged.

Check these conditions before making the election:

  • Measure the threshold against revenue, not profit.
  • Check revenue for the current tax period.
  • Check revenue for every previous tax period.
  • Confirm that the business is an eligible UAE resident person.
  • Exclude QFZPs and members of a qualifying Multinational Enterprise Group where the relevant exclusion applies.
  • Make the election inside the Corporate Tax return.

Small Business Relief is not automatic. If your business is eligible but does not make the election correctly, you may not receive the intended treatment.

Keep sales reports, payment records, marketplace statements and accounting records together. This will help you prove revenue accurately and complete the return without last-minute corrections.

Prepare for mandatory supplier verification from 1 October

FTA Decision No. 13 of 2026 takes effect on 1 October 2026. It introduces mandatory supplier and supply verification requirements for input VAT recovery under Article 54 bis of the UAE VAT framework.

The FTA may deny input VAT recovery where a supply chain involves tax evasion and the required checks were not completed and documented.

This is particularly relevant to businesses with large purchasing volumes, cross-border supply chains, marketplaces and fast-growing operating models.

Verify each supplier at the right time

Complete supplier verification:

  1. The first time you deal with a supplier.
  2. Again when 12 months have passed since the previous verification.
  3. More extensively when the relevant value thresholds apply.

Your supplier file should address:

  • Identity documents and official registration details.
  • The identity and authority of the supplier’s representative.
  • The supplier’s real place of business.
  • Changes of address.
  • Changes in key personnel.
  • Transactions that appear disproportionate to the supplier’s size or trading history.
  • Public reviews and media information where enhanced checks are required.

If annual supplies from one supplier exceed, or are expected to exceed, AED 375,000, obtain unqualified written confirmation from a UAE bank that the supplier holds an account there.

Verify the supply, not only the supplier

Supply verification applies to the commercial transaction itself. Document that:

  • There is a genuine commercial reason for the purchase.
  • The price is commercially justifiable.
  • The goods or services fall within the supplier’s licensed activities.
  • The title and origin of goods are sound.
  • Any intermediary has a clear commercial role.
  • Electronic payment was used, or the reason for cash payment is recorded.

Create a written verification policy as required by Article 5. The AED 10,000 de minimis exemption may apply to supplies below AED 10,000 excluding VAT. However, the exemption is disapplied once total supplies from that supplier exceed, or are expected to exceed, AED 100,000 over the preceding or following 12 months.

Once that cumulative threshold is reached, even smaller supplies from the same supplier require verification.

Track VAT Group exits and digital currency transactions

Two further VAT directives require operational changes.

Directive on Tax Transactions No. 2 of 2026 applies from 1 August 2026. If a former VAT Tax Group member remains VAT registered, it must report post-exit adjustments in its own VAT return.

Review transactions reported while the entity was part of the group. Track future credit notes, bad debt adjustments and input or output tax corrections so they are not incorrectly reported through the former group representative.

Directive on Tax Transactions No. 3 of 2026 clarifies how to convert digital currency into UAE dirhams for VAT purposes.

If you accept cryptocurrency as payment, review your conversion methodology. Keep consistent, time-stamped records showing the exchange rate, the conversion process and the AED value reported for VAT.

Start e-invoicing implementation now

The UAE e-invoicing programme is already moving through its pilot and voluntary phase, which began on 1 July 2026.

The current implementation timetable is:

  • Businesses with revenue of AED 50 million or more: appoint an Accredited Service Provider by 30 October 2026 and go live by 1 January 2027.
  • Businesses below AED 50 million: appoint an Accredited Service Provider by 31 March 2027 and go live by 1 July 2027.
  • Government entities: go live by 1 October 2027.

The system currently covers B2B and B2G transactions. B2C transactions are not currently included.

A PDF invoice emailed to a customer is not the same as a compliant e-invoice. You need structured electronic data that can move through the approved system.

Review your accounting platform, invoicing workflow, customer master data and supplier records now. Early preparation gives you time to appoint a provider, map mandatory fields and test data flows before the go-live date.

Read the UAE Ministry of Finance e-invoicing guidance for the latest technical and implementation information.

Check QFZP reporting requirements

Qualifying Free Zone Persons distributing goods in or from a Designated Zone should review