US: IRS extends treaty benefits to reverse foreign hybrids subject to branch profits tax
The IRS Chief Counsel ruled that reverse foreign hybrids may qualify for reduced branch profits tax on dividend equivalent amounts attributable to treaty-eligible owners. The US Internal Revenue Service (IRS) Chief Counsel has determined that
See MoreSingapore: IRAS updates guidance on foreign tax credit claims
The updated guidance now features a revised eligibility flowchart and provides clearer time limits for claiming a Foreign Tax Credit (FTC). The Inland Revenue Authority of Singapore (IRAS) has released revised guidance on claiming a Foreign Tax
See MoreArgentina: ARCA extends deadline for tax payment plan on incorrectly calculated losses
ARCA extends the deadline to 28 November 2025 for companies to join the payment plan for incorrectly calculated tax losses, allowing regularisation of debts with reduced down payments and up to 120 installments. The Argentine Revenue and Customs
See MoreUAE: Federal Tax Authority clarifies corporate tax rules for family wealth structures
The clarification explains how corporate tax applies to entities commonly found in family wealth management setups, such as Family Foundations, holding companies, Special Purpose Vehicles (SPVs), SFOs, and MFOs, as well as the family members
See MoreKenya: KRA consults significant economic presence (SEP) tax implementation
The consultation is set to conclude on 7 October 2025.Β The Kenya Revenue Authority (KRA) has initiated a public consultation on the released Draft Income Tax (Significant Economic Presence Tax) Regulations 2025, on 22 September 2025. These
See MoreSingapore: IRAS clarifies tax treatment of revaluation gains in company liquidation
IRAS rules revaluation gains on overseas shares in liquidation are not taxable. The Inland Revenue Authority of Singapore (IRAS) has issued Advance Ruling Summary No. 18/2025 on 1 September 2025, addressing the tax treatment of revaluation gains
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 MoreAustralia: ATO issues final guidance for the effective life of assets
The guidance helps determine how much of the assetβs cost taxpayers can claim as a tax deduction each year.Β The Australian Taxation Office (ATO) has published the final guidance for the effective life of depreciating assets on 23 September
See MoreKorea (Rep.): National Assembly proposes longer carryforward period for unused tech investment credits
The National Assembly is reviewing a bill to extend investment tax credit carryforwards from 10 to 20 years, effective retroactively from 2026. The Korean National Assembly is considering Bill No. 2212902Β which proposes extending the
See MoreUAE: FTA urges timely filing, payment of corporate tax to avoid penalties
Β The FTA explained that late submission of a Tax Return or a delay in settling the Corporate Tax Payable will result in an administrative penalty of AED 500 for each month, or part thereof, during the first 12 months, increasing to AED 1,000 for
See MoreTaiwan excludes unrealised foreign exchange gains from corporate tax
Unrealised foreign exchange gains and losses are excluded from Taiwanβs corporate income tax Taiwanβs Ministry of Finance announced on 12 September 2025 that unrealised foreign exchange gains and losses should not be included in the annual
See MoreGreece publishes 2023 preferential tax jurisdictions
Under Greek law, preferential tax regimes are those with a corporate tax rate equal to or less than 60% of Greeceβs rate for legal persons or permanent establishments.Β The Greek Public Revenue Authority (AADE) issued Decision No. A.1125 on 9
See MoreTurkey restricts simple method in business taxation
Certain businesses in metropolitan areas must use the real tax method from 2026. The Turkish government issued Presidential Decision No. 10380, published in the Official Gazette on 9 September 2025, introducing changes to business taxation under
See MoreTurkey: Government tightens criteria for simplified business taxation
The simple method allows eligible taxpayers to calculate business income by subtracting expenses from revenue without detailed accounting, provided they meet the participation, rental, turnover, and IIT exemption criteria. Turkeyβs government
See MoreSouth Africa: SARS consults on draft tax exemption guidanceΒ
Comments on the draft Note must be submitted by 10 October 2025. The South African Revenue Service (SARS) has initiated a public consultation on a draft interpretation note on the income tax exemption applicable to bodies corporate, share block
See MoreKenya: KRA imposes new cap on carryforward of prior losses
The ruling limits loss carryforwards, applying to losses from 1 July 2025 onward and retrospectively disallowing deductions for losses before the 2020 income year. The Kenya Revenue Authority (KRA) issued a private ruling on 1 September 2025
See MoreAustralia: ATO consults targeted taxpayer relief measures
The consultation is open from 4 September to 2 October 2025.Β The Australian Taxation Office (ATO) has initiated a public consultation on certain taxpayer relief measures, such as its approach to remission of interest and failure to lodge
See MoreAustralia: ATO finalises circumstances under which certain Division 7A notional loan repayments are disregarded
The guidance clarifies when certain Division 7A loan repayments for notional loans are disregarded for private companies.Β The Australian Taxation Office (ATO) has finalised its position on the circumstances under which certain Division 7A
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