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The ATO is seeking public feedback on a draft guidance to limit interest payment deductions on multinational debt.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 The Australian Taxation Office (ATO) has opened a public consultation regarding a draft guidance
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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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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
See MoreAustralia 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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