Canada consults draft legislations for corporate taxation, anti-avoidance rules and other measures
Canada’s Department of Finance launched a consultation on several draft legislative proposals to implement a range of previously announced tax measures on 29 January 2026. The proposed changes aim to clarify and improve tax rules, close gaps to
See MoreOECD: Presentation of the Side by Side Rules
On 13 January 2026 the OECD held a webinar to discuss the side-by-side arrangements issued earlier in the month. The side-by-side (SbS) arrangement would be available where a country’s tax regime has similar policy objectives and scope to the
See MoreOECD: Side by Side Arrangement on Global Minimum Tax
On 5 January 2026 the OECD issued a document with the title Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two), Side-by-Side Package. This document set out more details of the
See MoreBrazil mandates disclosure of ultimate beneficial owners of investment funds, companies
Brazil’s Federal Revenue Service published an update to the rule on 31 October 2025, which deals with the identification of the ultimate beneficiaries of investment funds, companies, and legal arrangements operating in the country. This measure
See MoreNetherlands revises business merger decree, defines tax and loss carry-forward rules
Decree 2025-219643 addresses business mergers, clarifies the tax treatment of cooperatives, updates loss carry-forward rules, and revises approval procedures. The Netherlands State Secretary for Finance published Decree 2025-219643 of 21 August
See MoreNetherlands: Lower house approves 2026 Omnibus Tax Bill
This 2026 Omnibus Tax Bill introduces various primarily technical, smaller-scale amendments, proposals, and corrections across multiple tax laws. The Dutch lower house of the parliament approved the 2026 Omnibus Tax Bill, and published it on its
See MorePoland: MoF consults functioning of General Anti-Tax Avoidance clause under Administrative Tax Code
Interested parties can submit their opinions by 8 October 2025. Poland’s Ministry of Finance and Economy has initiated a public consultation to evaluate the General Anti-Tax Avoidance (GAAR) clause, which was introduced in 2016 under the
See MoreEU Council stresses international tax cooperation and anti-evasion efforts in development financing
The EU Council released its conclusions and a press release on 26 May 2025, ahead of the 4th International Conference on Financing for Development. The Council of the European Union has released its conclusions and a press release on 26 May
See MorePhilippines enforces mutual assistance convention
The OECD-Council of Europe Convention on Mutual Administrative Assistance in Tax Matters, amended by the 2010 protocol, took effect in the Philippines on 1 May 2025. The Multilateral Convention on Mutual Administrative Assistance in Tax Matters
See MoreCyprus imposes new defensive tax rules on payments to low-tax and non-cooperative jurisdictions
Cyprus has published Laws No. 47(I)/2025 and No. 48(I)/2025 in the Official Gazette on 16 April 2025. These laws introduce updated defensive measures on outbound payments of dividends, interest, and royalties to non-cooperative or low-tax
See MoreAustralia: ATO announces amendments to its top 500 program
The Australian Taxation Office (ATO) has announced updates to its Top 500 Private Groups Tax Performance Program, effective 1 April 2025. About the Top 500 private groups tax performance program The Top 500 private groups tax performance
See MoreAustralia: ATO issues guidance on debt deduction rules
The Australian Taxation Office (ATO) has published guidance on Understanding the debt deduction creation rules (DDCR) to help determine if the DDCR applies to an entity and its related party financing arrangements. The guidance includes the
See MoreUS: House of Representatives reintroduces Unfair Tax Prevention Act bill to block extraterritorial taxes
Representative Ron Estes (R-Kansas) reintroduced the Unfair Tax Prevention Act in the US House of Representatives on 27 March 2025. Rep. Ron Estes (R-Kansas), joined by every Ways and Means Republican, reintroduced the Unfair Tax Prevention Act
See MoreAustralia: ATO cautions taxpayers on schemes avoiding division 7A compliance
The Australian Taxation Office (ATO) has issued a new taxpayer alert (TA2024/2) on 12 December 2024 targeting arrangements designed to bypass Division 7A requirements. The arrangements involve a profitable private company guaranteeing a loan made
See MoreUN: Resolution on Negotiating Committee for Framework Convention for International Tax Cooperation
On 14 October 2024 a Resolution was drafted by Nigeria on behalf of the Africa group at the UN, to adopt the terms of reference for the UN Framework Convention on International Tax Cooperation. The draft Resolution referred to the work of the Ad Hoc
See MoreUN Tax Committee: Issues in Extractive Industries Taxation
On 15 October 2024 the UN Tax Committee discussed developments in their work on extractive industries taxation. The work of the relevant subcommittee has focused on the energy transition; the valuation of mining products for tax purposes; and tax
See MoreAustralia consults expansion of penalty laws for tax exploitation scheme promoters
Australia’s government is requesting feedback on proposals to expand the penalty laws for promoters of tax exploitation schemes. The Treasury released the public consultation document on 4 October 2024, and interested stakeholders are
See MoreOECD: Tax Arbitrage Through Closely Held Businesses
On 7 October 2024 the OECD published a taxation working paper with the title Tax arbitrage through closely held businesses: Implications for OECD tax systems, written by Tom Zawisza, Sarah Perret, Pierce O’Reilly and Antonia Ramm. The working
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