Legislative Monitoring – International: July 2026

What's happening globally

Three main themes defined July. First, the restructuring of the US customs program onto a different legal basis: following a February US Supreme Court ruling that rejected measures based on the IEEPA Act, a temporary ten-percent surcharge under Section 122 was introduced; this expired on July 24 and was replaced the same night by more permanent measures under Section 301 and Section 338.

Second, a shift in export controls from named lists to ownership structure – the US rule on subsidiaries of listed entities is set to return on November 10, 2026, after a one-year suspension, and since July 1, China has been subjecting outbound investments that could affect its national security to a security review. Third, e-invoicing as a mandatory standard outside of Europe: in a single month, it advanced in Nigeria, Saudi Arabia, the Emirates, and Brazil.

For a company, these three themes converge on the price and throughput of a delivery: tariffs change calculations and cost allocation in contracts, vetting ownership structures prolongs closing, and e-invoicing determines the customer's right to a deduction. None of the measures are global – the rate, exemption, and deadline vary by country of origin, country of import, and sometimes by special zone. Therefore, always verify the national regime and the specific customs classification.

As of July 24, surcharges for goods entering the US also apply to goods from the European Union

On July 23, 2026, the Office of the United States Trade Representative (USTR) issued a final determination in 60 investigations under Section 301 of the Trade Act of 1974 concerning the ineffective ban on imports of goods produced by forced labor. The process was formal: investigations were initiated on March 12, 2026, actionability was determined on June 2, and the final determination was made after hearings and more than 1,600 comments. The tariffs apply to goods released for free circulation from 12:01 a.m. Eastern Time on July 24, 2026; goods in transit before this time are not subject, provided they were cleared by July 28.

There are two rates. Seventeen countries with an established ban on imports from forced labor – including Canada, Mexico, India, Indonesia, Malaysia, and the United Kingdom – pay a flat 10%. The remaining 38 countries, including China, Brazil, and Vietnam, pay 12.5%. For the European Union and Taiwan, the sum of the standard tariff and the surcharge will not exceed 10%, so if the standard tariff already reaches this ceiling, the surcharge does not apply; Japan, South Korea, and Switzerland have the same structure with a 12.5% ceiling. The measure applies to all products from a given country, with exceptions in the annexes, not to selected items – which is why this is the most sensitive change of the month for both exporters to the US and suppliers to American customers.

What your company should do now

• Review your ten highest-volume items imported into the US against Annexes I and II of the determination – the eight-digit or ten-digit tariff code is decisive, not the product category. This should be done by the sales department with the customs declarant within two weeks.

• Check framework agreements with US customers to see who bears the newly imposed tariffs; without a clause on cost-sharing in the event of a change in the customs regime, the surcharge typically falls on the supplier.

• Check your proofs of origin – assembly in China or Vietnam means 12.5% instead of the 10% ceiling for the EU.

As of August 19, not even the USMCA will protect your Canadian plant

On July 20, 2026, the US President signed three proclamations that, for the first time, used Section 338 of the Tariff Act of 1930 to impose a tariff rate – for example, the proclamation on dairy products, including an annex with tariff items, is publicly available, and the proclamations on alcoholic beverages and motor vehicles have a similar structure.

Selected Canadian goods – agricultural and dairy products, furniture, alcoholic beverages, and other items, totaling roughly $20 billion in annual imports – will be subject to an additional 50% tariff from 12:01 a.m. Eastern Time on August 19, 2026. According to the proclamations, the surcharge will apply regardless of whether the goods meet the USMCA rules of origin; energy products, potash, fish, critical minerals, and goods already subject to Section 232 measures are excluded.

A necessary caveat: Section 338 has never been used to impose tariffs, and open questions remain as to whether it has been superseded by the later Section 301 and whether the matter must first be investigated by the US International Trade Commission. Lawsuits at the US Court of International Trade are expected, and the court may overturn the measure, similar to the IEEPA tariffs. This affects a Czech company wherever it has a Canadian step in its US supply chain: a subsidiary, a distributor, a sub-supply finished in Canada, or warehousing before import.

What your company should do now

• Compare the tariff items of your Canadian supplies with the proclamation annexes and, for goods on the list, calculate the impact at 50%. This should be done by logistics by August 19.

• Evaluate expediting imports before August 19, verify the treatment of goods in a free-trade zone, and record the paid tariffs separately – if the court overturns the measure, this will be the basis for a refund.

The US has imposed tariffs of up to 100% on patented medicines, with a 15% rate for the EU

By a proclamation of April 2, 2026, the United States imposed a tariff of up to 100% under Section 232 on patented medicines and related inputs, including active ingredients and key starting materials. The measure is effective from July 31, 2026, for a group of large pharmaceutical companies listed in the annex, and from September 29, 2026, for other importers; a reduced rate of 15% applies to goods originating in the European Union, Japan, South Korea, Switzerland, and Liechtenstein.

However, the 100% rate is not universal: a different, lower rate applies to some other countries, companies with an approved plan to move production to the US have a preferential regime with a 20% surcharge, and companies that have also concluded a pricing agreement with the US Department of Health and Human Services pay no additional tariff at all. Generics, biosimilars, and their inputs are currently exempt, as are medicines of US origin and over 400 tariff items in a separate annex – the word "currently" is important, as the proclamation requires the Department of Commerce to reassess the status of generics within a year.

What your company should do now

• Sort your portfolio supplied to the US into patented and generic items, including active ingredients, and document their origin. This should be done by regulatory affairs with the customs declarant by September 29.

• Determine the tariff category of your US importer or client and, for contract manufacturing, verify whether the contract passes on the tariff cost.

Packages under $800 will not clear US customs without a customs declaration

On June 24, 2026, U.S. Customs and Border Protection (CBP) published two interim final rules that incorporated the previously only executive suspension of the administrative customs exemption for shipments up to $800 directly into customs regulations. For all modes of transport except international mail, the suspension is effective from June 24, 2026; for mail shipments, a new simplified customs procedure was created, effective from July 24, 2026, with a mandatory compliance date of October 22, 2026.

The statutory exemption itself will only be repealed by law – the One Big Beautiful Bill Act of 2025 – effective July 1, 2027; until then, CBP is changing the administrative conditions and types of declarations, not the statutory text. The new electronic declaration type for mail shipments (Entry Type 13) has been in the certification environment since July 24, and CBP will deploy it to the production environment on September 22, 2026; this is a voluntary test.

What your company should do now

• Add the ten-digit US tariff codes to your catalog for all items sold to the US – a customs declaration cannot be filed without them. This should be done by the product and logistics departments by October 22.

• Clarify with your carrier and customer who the importer of record is on the declaration, adjust the INCOTERMS delivery terms, and recalculate the price of small shipments to include duties and fees.

As of August, Brazil requires new fields for CBS and IBS in e-invoices

Brazil is continuing its transition to a dual consumption tax – the federal CBS and the state and municipal IBS. The implementing framework consists of Decreto n.º 12.955/2026 for CBS and Resolution CGIBS No. 6/2026 for IBS; on July 21, 2026, Decreto n.º 13.075 was published, amending the former. The year 2026 is a test period: CBS is reported at a rate of 0.9% and IBS at 0.1%, both fully offset against existing taxes, so the financial impact begins in 2027.

Ato Conjunto RFB/CGIBS No. 4 of July 30 established the obligation to fill in the CBS and IBS fields in the first wave of documents from August 3, 2026, but Ato Técnico Conjunto CGIBS/RFB No. 1 of July 31 postponed the effective date of the validation rules – so the obligation applies, but automatic rejection does not, and it is a postponement, not a waiver. The next deadline is October 1, 2026, for NFS-e documents subject to the ISS tax. For the first time, non-resident providers of digital and intangible services have a registration and reporting obligation, including registration in the CNPJ system before starting operations.

What your company should do now

• If you sell software, SaaS, or licenses to Brazil, verify the CNPJ registration and CBS/IBS reporting requirements. The CFO is responsible.

• Instruct your ERP provider to add the CBS and IBS fields to the XML structures and test them while the validation rules are not yet in effect. This should be done by October 1, when the NFS-e wave with the ISS tax begins.

• Review your Brazilian contracts that refer to ICMS, ISS, PIS, or COFINS – these taxes are being phased out, and the references will become obsolete.

As of July 1, a Chinese investment in your company could get stuck in a security review in Beijing

On April 17, 2026, the Chinese State Council adopted regulations on outbound investment, which the Premier signed as Decree No. 837 on May 5 and which were published on June 1, 2026, with an effective date of July 1, 2026. The regulation has 34 articles and is the State Council's first standalone regulation on outbound investment. Article 13 prohibits Chinese investors from exporting or using goods, technologies, services, and data whose export is prohibited or restricted under Chinese law – including indirectly, through cross-border training, technical guidance, personnel secondment, or remote technical support.

Article 15 introduces a security review mechanism; note its scope, as it is not an automatic review of every investment, but a review of those investments and transfers that may affect China's national security.

The practical impact for a Czech party is transactional: if a Chinese investor is acquiring a stake in your company or a Chinese partner is contributing technology, documentation, or a dataset, a missing permit on the Chinese side can block the closing or make performance after signing impossible.

What your company should do now

• Add a representation and warranty to your transaction documentation stating that the Chinese counterparty has all the necessary permits under the outbound investment regulations, and make it a condition precedent to closing.

• For ongoing joint ventures, map what technical support, training, and data flow across the border – the regulation also covers intangible transfers without a formal investment – and get written confirmation as to whether the transaction is subject to a security review.

Your Australian subsidiary must pay superannuation within seven working days of payday

As of July 1, 2026, the Payday Super regime is in effect in Australia. Mandatory superannuation contributions are no longer paid quarterly and must be credited to the employee's fund account within seven working days of each payday; details are provided in the implementing regulation, the Treasury Laws Amendment (Payday Superannuation) Regulations 2026.

A "qualifying earnings" base is being introduced, which includes ordinary time earnings, commissions, some salary sacrifice amounts, and payments to contractors who are considered employees for superannuation purposes. The Australian Taxation Office (ATO) supervises compliance through the Single Touch Payroll system, and the penalty is the Superannuation Guarantee Charge plus interest. The crucial point is how the deadline is calculated: it runs from the payday until the payment arrives at the fund, not when the employer sends it – and clearing can take several working days.

What your company should do now

• Test one real pay cycle and measure how many working days it takes for the payment to be credited to the fund. If you can't make it within seven, move up the dispatch time. This should be done by the payroll department immediately.

• Check that your payroll system calculates the contribution from the new base, and review contracts with Australian contractors – if they are considered employees for superannuation purposes, a contribution obligation arises for them as well.

Saudi Arabia has finally specified where you can buy real estate

The law on real estate ownership by non-Saudis was published in the official gazette on July 25, 2025, and came into effect 180 days later, in January 2026; it replaced the individual permit regime. The missing piece was supplied by the Council of Ministers on June 23, 2026, when it approved the implementing regulations and confirmed the geographical zones where non-Saudis can acquire real estate and property rights. Registration, payment, and title issuance all take place through the central electronic platform of the Real Estate General Authority (REGA).

The framework distinguishes between foreign legal entities, Saudi companies with foreign participation, and listed vehicles and funds, which opens up various acquisition and holding structures. An unlisted Saudi company with a foreign owner can acquire real estate even outside the designated zones – for its business activities or for employee housing – but outside the zones, this requires prior approval from the Ministry of Investment (MISA); within the zones, it does not.

A resident individual may own one residential property outside the zones. Mecca and Medina remain restricted. In addition to the five-percent real estate transaction tax (RETT), a special REGA fee applies to dispositions, currently 2% for Riyadh, Jeddah, Mecca, and Medina. Registration is a condition for legal effect, and property acquired based on false information may be sold at public auction.

What your company should do now

• Before signing, verify that the specific parcel is located in a designated zone, and factor both the five-percent RETT and the two-percent REGA fee into your model. The investment team is responsible.

• Decide on the acquisition structure, include MISA approval as a condition precedent for acquisitions outside the zones, and address the allocation of the new fee in the contract.

Saudi e-invoicing extends to smaller companies, ZATCA waives penalties until year-end

Here, two common assumptions need to be corrected. The deadline for the integration of entities included in the 24th wave (VAT-able turnover above SAR 375,000) was June 30, 2026, but the system's expansion did not end there: on July 24, 2026, the Saudi Zakat, Tax and Customs Authority (ZATCA) announced the 25th wave with a halved threshold of SAR 187,500 for any year from 2022 to 2025 and an integration deadline of February 1, 2027; affected entities will be notified at least six months in advance. At the same time, the Minister of Finance decided to extend the penalty waiver initiative for another six months, from July 1 to December 31, 2026.

Therefore, it is not true that full enforcement without the possibility of a waiver applies from July 1 – however, for penalties related to e-invoicing, you should verify the scope of this year's waiver directly with ZATCA, as the announcement does not explicitly mention them. The substantive regime remains unchanged: standard B2B and B2G invoices are subject to a clearance regime, the document must be approved by the tax authority before being issued to the customer, simplified documents are reported within 24 hours, and paper or PDF invoices are not valid.

What your company should do now

• Find out if your Saudi entity falls into the 25th wave – the SAR 187,500 threshold affects even very small entities, and the integration deadline is February 1, 2027. The CFO is responsible.

• Take advantage of the extended penalty waiver until December 31, 2026, to rectify any shortcomings; the conditions are registration, filing of all returns, and payment of the principal tax amount.

Your Nigerian subsidiary should have had e-invoicing ready by July 31

In a public notice dated February 17, 2026, the Nigeria Revenue Service (NRS) established a phased schedule for mandatory e-invoicing in the Merchant Buyer Solution system. For large taxpayers – companies with an annual gross turnover of NGN 5 billion or more – the full compliance deadline was July 31, 2026, and the NRS announced in July that it had already begun compliance checks; medium taxpayers are onboarding from July 1, 2026, and emerging taxpayers from July 1, 2027.

The legal basis is Section 23 of the Nigeria Tax Administration Act and Section 158 of the Nigeria Tax Act. Compliance means more than just registration: the NRS requires connecting the accounting or ERP system through an approved access point provider, completing validation and testing, actively transmitting invoices to the platform, and the taxpayer must accept only documents with a valid Invoice Reference Number (IRN) from suppliers.

Non-resident suppliers are currently exempt, although the tax authority is considering their inclusion – so the risk lies with the customer, as supplier non-compliance affects input VAT reconciliation and the smoothness of a tax audit.

What your company should do now

• If your group has a Nigerian entity, find out which taxpayer category it falls into and verify its connection status; for large taxpayers, the deadline was July 31, and audits are already underway.

• For Nigerian distributors, obtain proof of connection and add an obligation to supply documents with a valid IRN to your contracts.

Kenya may reclassify your digital platform payment as a royalty

The Kenyan President signed the Finance Act, 2026 on June 23, 2026, and most provisions took effect on July 1, 2026; some are postponed to September 1, 2026, and January 1, 2027. The Act amends seven tax laws, including the Income Tax Act, the VAT Act, and the Tax Procedures Act. For foreign suppliers, the most important change is the expansion of the definitions of "management or professional fees" and "royalties" to include payments for payment networks, payment transaction processing, and broader fees for digital platforms; the withholding tax on royalties for non-residents is 20%.

Be careful with interpretation. It is not the case that every payment for a digital or platform service is now a royalty subject to a 20% withholding tax – Kenyan law still distinguishes between royalties, management and professional fees, and VAT on digital services, with each category having its own regime, and the substance of the service, not its commercial name, is decisive. However, the expanded definitions mean that a payment previously sent as a regular service fee may be reclassified – and this will be done by the payer or the tax authority, not you.

The Act also introduces a self-assessment regime for non-residents with real estate income in Kenya, with a monthly return and payment by the 20th of the following month, repeals the preferential 5% withholding tax on dividends for citizens of the East African Community, and expands the tax authority's assessment powers to include data from third-party reports and e-TIMS invoices. Additionally, from September 1, 2026, import documentation and the export declaration regime will change.

What your company should do now

• Review your contracts with Kenyan customers and have each service assessed to determine which category it falls into; without a gross-up clause, you will bear any withholding tax. This should be done by the CFO with the legal department.

• For group and license payments, verify the possibility of applying a double taxation treaty, and by September 1, update your import documentation and export declarations with your carrier.

What to just monitor for now in other jurisdictions

• Emirates: Entities with a turnover of AED 50 million or more must appoint an accredited e-invoicing provider by October 30, 2026, and launch the system on January 1, 2027; others by March 31, 2027. The obligation also applies to non-residents registered for VAT in the UAE. The penalty is AED 5,000 for each month of delay. The voluntary phase has been running since July 1, 2026 – use it to clean up your master data.

• Japan: The parliament passed an amendment to the Foreign Exchange and Foreign Trade Act (FEFTA) on May 29, 2026, promulgated on June 5. It will take effect on a date to be set by a government ordinance, within one year of promulgation; draft implementing regulations were under consultation until August 2, 2026. The amendment includes indirect acquisitions in the screening process – for planned acquisitions of a Japanese target or a group with a Japanese subsidiary, plan your timeline for both effective date scenarios.

• India: The second stage of the rules for the Digital Personal Data Protection Act (DPDP Rules) begins on November 13, 2026, with full substantive obligations from May 13, 2027, and fines of up to INR 250 crore. Anyone with an Indian subsidiary or Indian customers now has time for a data inventory.

• Australia: The second wave of AML/CTF reform expanded the scope of regulated services from July 1, 2026, to include real estate agents, buyers' agents, developers, lawyers, and accountants. The decisive factor is not the profession, but the provision of one of the defined "designated services" with a sufficient link to Australia. For developers, this means a longer onboarding process and new requirements to document ownership structure and source of funds.

In New Zealand, Egypt, the Kingdom of Morocco, and the Republic of South Africa, no new developments with a sufficiently significant cross-border impact on the target segment were identified as of the closing date.

Deadlines for companies to watch in the next 90 days

Final summary

The US customs measures require an immediate response: the Section 301 surcharge is already in effect, so there is no point in delaying decisions on tariff allocation in contracts and pricing, and Canadian goods must be classified before August 19. The US mail customs procedure is equally urgent, as shipments cannot be sent at all without tariff codes.

Five deadlines require preparation before they take effect: September 29 for pharmaceutical tariffs on other importers, October 30 for the Emirati e-invoicing provider, December 31 as the end of the Saudi penalty waiver, February 1, 2027, for the integration of the 25th wave, and November 10, when the US rule extending export controls to subsidiaries of listed entities is set to return after a one-year suspension. It is most advantageous to use the latter now – to map the ownership structures of customers while the licensing obligation is not yet in effect.

Local verification is required for the zonal classification of a Saudi parcel, the scope of this year's Saudi penalty waiver, and the Kenyan classification of individual services. Legal uncertainty is a separate category: the US tariffs under Section 338 are based on a provision that has never been used for this purpose, and the Brazilian postponement of validation rules could be shortened – base your decisions on the current situation, but keep your records in a way that can withstand a change.

Recommendation for management decision-making: select the three countries where you have the largest volume or the largest ongoing transaction, and have them go through this entire agenda as a priority. Trying to cover all jurisdictions at once usually ends with not even managing the one where the money is actually flowing.

Are you dealing with tariffs and cost allocation in export contracts, a subsidiary, sanctions screening of a counterparty, or a cross-border acquisition? Email us at consultation@arws.cz. The lawyers at ARROWS law firm will assess your situation and, for projects in multiple countries, coordinate the individual jurisdictions through the ARROWS International network. For professional liability purposes, ARROWS law firm is insured with a limit of CZK 350,000,000.