Ireland: Irish Revenue updates Pillar Two guidance
The updated guidance outlines Pillar Two registration, filing, and top-up tax requirements for MNEs. Irish Revenue published updated guidance on Pillar Two requirements on 14 August 2025, covering an overview of Pillar Two, registration
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Australia: ATO issues final compliance guideline on restructures and updated thin capitalisation rules
This guideline outlines ATO’s practical compliance approach for restructures undertaken in response to the new thin capitalisation and debt deduction creation rules (DDCR). The Australian Taxation Office (ATO) has published the final
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Sweden: Ministry of Finance proposes amendments to global minimum tax rules
The draft legislation aligns Sweden’s Top-up Tax Act with new OECD guidance and EU rules on global minimum taxation. Sweden’s Ministry of Finance published draft legislation on 14 August 2025 to amend Act (2023:875) on top-up tax for
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India introduces Pillar Two disclosure requirements under national accounting standard
India has amended Ind AS 12 to align with International Accounting Standard 12 and introduce new disclosure requirements for the OECD’s Pillar Two global minimum tax. India’s Ministry of Corporate Affairs has issued the Companies (Indian
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Chile clarifies indirect foreign tax credit treatment for CFCs
Ruling No. 1500-2025 confirms that the indirect foreign tax credit applies only if a treaty or information exchange agreement exists and the CFC owns at least 10% of the subsidiary. Chile’s tax administration (SII) issued Ruling No. 1500-2025
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Czech Republic: Senate approves updated deadlines for Pillar Two tax reporting
The Senate amended the Act on top-up taxes, extending first-time filing deadlines for the top-up tax information return and top-up tax return. The Czech Senate has approved an amendment to the Act on top-up taxes, extending the deadlines for the
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Taiwan: MoF clarifies direct and indirect holdings count in CFC rules
The finance ministry confirms both direct and indirect related-party ownership count when determining CFC status in low-tax jurisdictions. Taiwan’s Ministry of Finance has released a statement on 31 July 2025 clarifying that in assessing
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Switzerland clarifies top-up tax treatment of residual tax on distributions
Switzerland confirms treatment of residual tax on distributions for top-up tax calculations effective from 1 January 2024. The Swiss Federal Tax Administration released Communication-026-E-2025-e on 24 July 2025, clarifying the treatment of
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Italy implements emergency tax revisions on CFC, hybrid mismatch penalty rules
Urgent tax measures include revising the domestic CFC rules, tax loss carry-forward provisions, and the penalty protection regime for hybrid mismatch assessments. Italy’s parliament converted Law Decree No. 84 of 17 June 2025 into law with
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Taiwan: MOF tightens CFC loss submission rules
The finance ministry mandated that CFC losses are deductible only if audited statements or equivalent proof are filed by the tax deadline (plus a one-time six-month extension); otherwise, they're disallowed. Taiwan’s Ministry of Finance has
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Panama withdraws extended deadlines for tax treaty claim corrections
The new resolution only allows a 10-day extension, with the possibility of extending it up to 30 days. Panama published Resolution No. 201-5822 on 16 July 2025, in Official Gazette No. 30323, repealing Resolution No. 201-2232 of 16 March
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Taiwan: MoF warns enterprises on timely CFC loss reporting
The finance ministry stated that CFC losses need supporting documents by the tax deadline, or they won’t be allowed. Taiwan’s Ministry of Finance (MOF) stated that CFC losses will be disallowed unless supporting documents are submitted by the
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Taiwan issues CFC exemption guidelines for 2025 compliance
New guidance confirms Taiwan’s CFC exemption applies to entities with limited earnings or substantial operations. Taiwan’s Ministry of Finance has released a notice to specify the exemption limit for current-year income under the Controlled
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Tanzania enacts 2025-26 budget measures, includes new transfer pricing penalty
The measures will apply from 1 July 2025, unless otherwise specified. Tanzania's Finance Act 2025 was enacted on 30 June 2025, implementing tax measures from the 2025-26 Budget Speech with some adjustments to the initially announced
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Italy amends CFC rules, tax loss carry-forward provisions
The adopted tax measures include updates to controlled foreign company (CFC) rules and tax loss carry-forward provisions. Italy has published Decree No. 84 of 17 June 2025 in Official Gazette No. 138 on 17 June 2025, introducing changes to the
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Kazakhstan revises tax treaty list for CFC rules
Kazakhstan has updated its list of jurisdictions eligible for CFC rule exemptions, removing several countries and Swiss cantons, effective 22 May 2025. Kazakhstan issued Order No. 247 on 22 May 2025, amending Order No. 680 of 19 June 2023. The
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Denmark: Parliament approves changes to Pillar Two minimum tax, Pillar One Amount B, related measures
The Parliament approved Bill L 194A on 3 June 2025. Denmark’s parliament has approved Bill L 194A, amending the Minimum Taxation Act, Corporate Tax Act, and other laws on 3 June 2025. Minimum Taxation Act and Corporate Tax Act The
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Australia: ATO consults thin capitalization compliance guide
The ATO is seeking public feedback on a draft guidance to limit interest payment deductions on multinational debt. Comments are due by 30 June 2025. The Australian Taxation Office (ATO) has opened a public consultation regarding a draft guidance
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