UN: New Article 12AA on Taxation of Services Presented for Approval
The 30th session of the UN Committee of Experts on International Cooperation in Tax Matters is being held from 24 to 27 March 2025. On 25 March 2025 the Subcommittee on Taxation Issues Related to the Digitalized and Globalized Economy presented
See MoreOECD: Report on Simplified Peer Review of Iceland under BEPS Action 14
On 4 March 2025 the OECD issued a stage one simplified peer review report on Iceland under BEPS action 14. The report sets out the results of Stage 1 of the simplified peer review of the implementation of the minimum standard on making dispute
See MoreOECD: Report on Simplified Peer Review of Peru under BEPS Action 14
On 4 March 2025 the OECD issued a stage one simplified peer review report on Peru under BEPS action 14. The report sets out the results of Stage 1 of the simplified peer review of the implementation of the minimum standard on making dispute
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Italy: Finance department clarifies general anti-avoidance rule
Italy’s finance department has issued guidelines on applying the general anti-avoidance rule (GAAR) under article 10-bis of Law No. 212 of 27 July 2000 on 27 February 2025. The document outlines the abuse of law doctrine and examines the key
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Australia updates form, instructions for thin capitalisation test choice
The Australian Taxation Office (ATO) has updated its form and instructions for taxpayers on 13 February 2025, allowing individuals to select either the group ratio test or the third-party debt test (thin capitalisation test choice) for a specific
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Ireland: Revenue updates CFC rules in eBrief 023/25
The Irish Revenue released eBrief 023/25 on 24 January 2025, which includes updates to the tax and duty manual on Controlled Foreign Company (CFC) rules, in light of the changes introduced by the Finance Act 2024. Tax and Duty Manual - Part
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Chile clarifies CFC rules, updates preferential tax jurisdictions
Chile’s tax administration published Circular Letter 11/2025 on 30 January 2025, which introduced Law 21.713, regarding controlled foreign company (CFC) regulations, preferential tax regimes, and the indirect sale of assets in Chile. The Law
See MoreAustralia: ATO targets thin capitalisation in trust reviews
The Australian Taxation Office (ATO) has announced on 30 January 2025 regarding its focus on the updated thin capitalisation rules as part of its justified trust reviews. Thin capitalisation in focus for justified trust reviews How we're
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Indonesia updates CRS participating and reportable jurisdictions for 2025
Indonesia's Directorate General of Taxes has published Announcement No. 1/PJ/2025 on 24 January 2025, listing the participating and reportable jurisdictions for the 2025 automatic exchange of financial account information under the Common Reporting
See MoreItaly announces qualified jurisdictions for supplementary, national minimum tax
Italy’s Ministry of Economy and Finance has published a list of jurisdictions, on 23 January 2024, that have enacted supplementary minimum tax and national minimum tax laws. These jurisdictions have obtained the transitional “qualified” status
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Ecuador updates tax haven and preferential regime guidelines
Ecuador's Internal Revenue Service (SRI) has published Circular NAC-DGECCGC25-00000002 on 21 January 2025, outlining new guidelines for identifying tax havens, preferential tax regimes, and low-tax jurisdictions. A regime or or jurisdictions
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Taiwan updates low-tax jurisdictions list
Taiwan's Ministry of Finance (MOF) released an updated list of low-tax jurisdictions on 27 December 2024. Controlled Foreign Company (CFC) rules, which have been in effect in Taiwan since the 2023 tax year, were introduced to prevent companies or
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Ukraine suspends CFC reporting fines during martial law
Ukraine’s president, Volodymyr Zelensky has signed Law No. 9319 on 25 December 2024 which postpones a new military tax hike for small businesses and individual taxpayers until 1 January 2025. Under this law, Ukrainian residents will not be fined
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Russia: MoF clarifies loss carry-forward rules for CFCs redomiciled as international companies
The Russian Ministry of Finance (MoF) clarified in Guidance Letter No. 03-12-11/2/107192, published on 9 December 2024 that, under certain conditions, losses can be carried forward by a controlled foreign company (CFC) registered in Russia and
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Australia: ATO consults implementation of thin capitalisation third-party debt test
The Australian Taxation Office (ATO) has initiated a public consultation regarding the implementation of the thin capitalisation third-party debt test . Additionally, it addresses the associated Schedule 3 of Draft Practical Compliance Guideline
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Belgium publishes guidance on new CFC rules
Belgium’s tax authorities have issued two circular letters - Circular 2024/C/82 and Circular 2024/C/83 - on 13 December 2024 - providing clarity on specific aspects of the controlled foreign company (CFC) rules introduced in 2023. The amended
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Austria updates CFC rules to prevent double taxation under Pillar Two
Austria's parliament has amended its CFC rules to avoid double taxation issues under the Pillar Two global minimum tax framework. Amendments to Section 10a of the Austrian Corporate Income Tax Act have been approved and now require Qualified
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Slovenia proposes changes corporate income tax law
Slovenia's government has presented a draft bill (EVA: 2024-1611-0039) to the parliament on 25 October 2024, proposing several amendments to the corporate income tax law. Tax loss carry-forward limitation The bill suggests limiting the
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