Poland: 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
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EU 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
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Cyprus 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
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Australia: 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
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US: 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
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UN: 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
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UN 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
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Australia 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
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OECD: 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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United Kingdom: NAO Report on Tax Evasion in the Retail Sector
On 9 September 2024 the National Audit Office (NAO) issued a report on tackling tax evasion in high street and online retail. The report examines how well HMRC understands and assesses the risk of tax evasion in retail; and looks at its strategy
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OECD: Further Reviews of Harmful Tax Practices
On 27 August 2024 the OECD released an update on the reviews by the Forum on Harmful Tax Practices of aspects of the tax regimes of some member countries of the Inclusive Framework under Action 5 of the project on base erosion and profit shifting
See MoreUS: TIGTA urges IRS to review procedures on MNCs tax avoidance strategies
The Treasury Inspector General for Tax Administration (TIGTA) has recommended the Internal Revenue Service (IRS) to reassess its examination procedures to effectively address the tax avoidance strategies employed by large multinational corporations
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US: IRS struggles to tackle tax avoidance by multinational corporations
The US Treasury Inspector General for Tax Administration (TIGTA) issued a partially redacted report on 26 August 2024, highlighting the challenges the US Internal Revenue Service (IRS) encounters in tackling tax avoidance strategies deployed by
See MoreAustralia: Guidance on Thin Capitalisation Rules Published Online
Following the enactment of the new thin capitalisation laws in April 2024, the ATO has developed web guidance to assist taxpayers in applying the new rules, which are effective for income years commencing on or after 1 July 2023. Under the rules,
See MoreEU Commission reviews anti-avoidance tax directive
The European Commission has announced an initiative to evaluate the Anti-Avoidance Tax Directive (ATAD), which will also include a public consultation. The ATAD lays down minimum standard rules to address the most common forms of aggressive tax
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UN: Ad Hoc Committee Discusses Issues for Early Protocols
Following an earlier Resolution on international tax cooperation and a report by the Secretary General setting out options going forward, UN Resolution 78/230 of 22 December 2023 established an ad hoc intergovernmental committee to draft terms of
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