International Corporate Structuring: Tax Transformation and New Rules for AI and Crypto

An online meeting took place as part of the ITU Global Talks international webinar format, organised by the IT Ukraine Association with the participation of ITU Partner Juscutum. The topic of the meeting was ‘ ‘International Corporate Structuring: Key Considerations for 2026’. 

 

 

The speaker of the event Petro Bilyk, Partner of the Technology&Investment Practice at Juscutum, outlined the key developments shaping the global regulatory and tax environment. These included the evolving regulatory landscape for AI, crypto and digital services, the implementation of Pillar Two in the EU, US R&D incentives under Section 174A, the extension of the EU AI Act to high-risk AI systems, CE marking requirements under the Cyber Resilience Act, enhanced crypto transparency obligations under DAC8 and the full implementation of MiCA across the EU, as well as new requirements under the EU Pay Transparency Directive and the UK Employment Rights Act 1996.

 

Among the information shared:

 

Global Tax Transformation

• The EU’s Pillar Two framework introduces a 15% global minimum tax for multinational groups, including structures in jurisdictions such as Cyprus. This must be carefully considered when designing and reviewing international corporate models.
• In the United States, Section 174A provides the opportunity to obtain a 100% deduction for qualifying domestic R&D expenditure, subject to meeting the relevant statutory requirements.
• In the UAE, compliance with the Qualifying Free Zone Person (QFZP) criteria may enable a 0% corporate tax rate, making the jurisdiction attractive for businesses with genuine economic substance.

AI, Crypto and Digital Services — A New Regulatory Landscape

• The EU AI Act, effective from 2 August 2026, applies to high-risk AI systems (ranging from HR solutions to FinTech), introducing mandatory compliance requirements.
• The Data Act requires SaaS providers to review and update their terms of service by September 2026.
• The Cyber Resilience Act introduces mandatory CE marking for products with digital elements from 2027, alongside vulnerability reporting obligations starting in September 2026.
• From 1 January 2026, tax anonymity in the crypto sphere effectively ends. DAC8 requires the collection of comprehensive user data by crypto service providers, with the first reporting deadline set for 31 January 2027.
• The year 2026 marks the full implementation of Markets in Crypto-Assets Regulation (MiCA) across all EU Member States, introducing mandatory licensing for Crypto-Asset Service Providers (CASPs), capital requirements and obligations to prepare white papers for token issuances.

Employment Law Developments

• The EU Pay Transparency Directive, effective from June 2026, requires mandatory disclosure of salary ranges in job vacancies, grants employees the right to request information on average pay levels, and introduces gender pay gap reporting obligations.
• In the United Kingdom, the Employment Rights Act 1996 provides protection against unfair dismissal from day one of employment, significantly affecting hiring and termination practices, particularly for start-ups.

 

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