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
See MoreTaiwan: 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
See MoreTaiwan 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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Netherlands: Tax Administration clarifies domestic withholding exemption may apply to outbound dividends despite treaty ineligibility
The Tax Administration has clarified its position on whether dividends can qualify for a withholding tax exemption under Article 4(2) of the Dividend Withholding Tax Act if they don’t qualify for treaty benefits. The Dutch Tax Administration
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New Zealand consults thin capitalisation reforms to attract infrastructure investment
New Zealand’s Inland Revenue invites feedback on proposed changes to thin capitalisation rules to encourage foreign investment in private infrastructure projects. Submissions are open until 19 June 2025. New Zealand’s Inland Revenue has
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Belgium: Government presents tax reform plan to parliament, includes VAT measures
The Belgian Chamber of Representatives has released a policy note on 24 April 2025 detailing its tax reform plans for the upcoming year. The key measures of the tax reform plan include: Dividends received deduction rules Enhancing the
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Argentina sets rules for using reconstruction bonds to pay taxes and customs debts
Argentina’s tax authority (ARCA) has announced  the regulations for companies and individuals to use Bonds for the Reconstruction of a Free Argentina (BOPREAL) to settle tax and customs debts through General Resolution 5675/2025 on 16 April
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Ireland: Revenue issues guidance on general anti-avoidance rule and protective notifications
Irish Revenue has published eBrief No. 085/25 on 16 April 2025, introducing a new Tax and Duty Manual Part 33-02-03, which offers guidance on the general anti-avoidance rule and the use of protective notifications. This manual provides guidance
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