Australia: ATO updates guidance on global and domestic minimum tax
The Australian Taxation Office has updated the guidance on the Global and Domestic Minimum Tax on 23 December 2024. This includes the subordinate legislation which outlines detailed computational rules under the Taxation (Multinational—Global and
See More
Denmark, Greenland: Amending protocol to tax treaty enters into force
The amending protocol to the 1979 income and capital tax treaty between Denmark and Greenland came into force on 19 December 2024. The new protocol incorporates the DBO of the OECD’s BEPS minimum standards (Base Erosion and Profit Shifting),
See More
US partially suspends tax treaty with Belarus
The US Internal Revenue Service (IRS) has released Announcement 2025-5, confirming the partial suspension of the 1973 tax treaty with the former Soviet Union as it pertains to Belarus. The US provided formal notice to the Republic of Belarus on
See More
Ukraine suspends CFC reporting fines during martial law
Ukraine’s president, Volodymyr Zelensky has signed Law No. 9319 on 25 December 2024 which postpones a new military tax hike for small businesses and individual taxpayers until 1 January 2025. Under this law, Ukrainian residents will not be fined
See More
Netherlands updates tax penalty rules
The Netherlands State Secretary for Finance has published Decree No. 2024-15074 of 18 December 2024 in the Official Gazette on 31 December 2024, outlining various tax penalties which include several penalty increases effective from 1 January
See More
UN: General Assembly approves negotiations for global tax cooperation framework
The UN General Assembly adopted a resolution establishing the terms of reference for a United Nations Framework Convention on International Tax Cooperation. The resolution passed with 119 countries voting in favor, 9 opposed, and 43
See More
Poland sets base and margin rates for transfer pricing
Poland has published Notice No. 1105 in the Official Gazette on 21 December 2024, setting the base interest rates and margin interest rates for transfer pricing in individual and corporate income taxes. The regulation establishes base interest
See More
Germany: Federal Council approves revised Bill for tax law advancements, income tax adjustments
The German Federal Council (Bundesrat) approved the updated version of the bill aimed at further developing tax law and adjusting the income tax brackets on 20 December 2024. It will enter into force after publication in the Official Gazette. The
See More
Russia: MoF clarifies loss carry-forward rules for CFCs redomiciled as international companies
The Russian Ministry of Finance (MoF) clarified in Guidance Letter No. 03-12-11/2/107192, published on 9 December 2024 that, under certain conditions, losses can be carried forward by a controlled foreign company (CFC) registered in Russia and
See More
Thailand introduces Pillar Two top-up tax for MNEs
Thailand's Revenue Department has announced the publication of the Emergency Decree on Top-up Tax B.E. 2567 (2024) in the Official Gazette on 26 December 2024,introducing the implementation of a domestic minimum top-up tax for MNE groups with a
See More
Ireland: Revenue issues guidance on new VAT scheme for SMEs
Irish Revenue issued eBrief No. 315/24 on 13 December 2024 which outlines the European Union (EU) Value Added Tax (VAT) scheme for small and medium-sized enterprises (SMEs) effective from 1 January 2025. Currently, Member States can set their
See More
Peru raises tax unit value (Unidad Impositiva Tributaria) for 2025
Peru has increased the value of its Tax Unit (Unidad Impositiva Tributaria - UIT) for the 2025 fiscal year. The value will rise from PEN 5,150 to PEN 5,350, as outlined in Supreme Decree No. 260-2024-EF. This announcement was published on 17
See More
Singapore: IRAS publishes new guidance on MNE top-up tax, domestic top-up tax
The Inland Revenue Authority of Singapore (IRAS) has released a new e-Tax Guide on the Multinational Enterprise (MNE) Top-up Tax (MTT) and Domestic Top-up Tax (DTT) on 31 December 2024. This e-Tax guide sets out the key parameters of the MTT and
See More
Oman introduces Domestic Minimum Top-Up Tax for MNEs
The Oman Tax Authority has confirmed that a Royal Decree has been issued which implements a domestic minimum top-up tax, with a minimum effective tax rate of 15%, for multinational enterprise (MNE) groups in Oman, provided that these groups
See More
Kuwait introduces supplementary domestic minimum top-up tax for MNEs
Kuwait's Ministry of Finance announced on X that a supplementary domestic minimum top-up tax (DMTT) for large multinational enterprises (MNEs) has been introduced through Decree No. (157) of 2024 on 30 December 2024. The Decree is designed to
See More
Italy issues decree on Pillar Two rules, deferred tax attributes on transition
Italy’s Ministry of Economy and Finance has published the Ministerial Decree of 20 December 2024 in Official Gazette No. 304 of 30 December 2024. The Decree outlines additional implementation rules for the top-up tax introduced under Legislative
See More
Norway publishes overview of tax changes for 2025
Norway’s government has released an overview outlining key tax changes which took effect on 1 January 2025. Some of the main changes include: Natural resource tax for hydropower The natural resource tax for hydropower plants has been
See More
Brazil: Revenue authority publishes updated guidance on commodities transfer pricing
Brazil’s revenue authority (Receita Federal) has issued new guidelines for Normative Instruction RFB No. 2246 of 30 December 2024, outlining rules for companies regarding the management of transfer pricing for transactions that involve commodities
See More