Australia: ATO issues guidance for private groups seeking to claim debt deductions
The Australian Taxation Office has released guidance on 14 November 2025, offering practical tips for private groups seeking to claim debt deductions. When preparing a tax return, private groups must make sure they check if the thin
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Finland: Parliament reviews amendments to permanent establishment income allocation rules
Finland’s Parliament is reviewing draft bill HE 164/2025 vp, which proposes amendments to domestic regulations on attributing profits to permanent establishments on 12 November 2025. The proposal suggests amending the Income Tax Act, the Act on
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Czech Republic confirms defence tax covered by double taxation treaty with Japan
The Czech Republic’s Ministry of Finance has announced, on 5 November 2025, that Japan’s recently introduced Special Corporation Tax for Defence will be recognised under the existing double taxation treaty between the two countries. According
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Finland: MoF consults on proposed amendments to the minimum tax act for large corporate groups
Finland’s Ministry of Finance has launched a public consultation on proposed changes to the Minimum Tax Act on 11 November 2025 to maintain compliance with the EU Minimum Tax Directive (2022/2523). The legislative change would ensure that
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Slovak Republic publishes legislation to enact DAC9, Pillar 2 administrative guidance
The Slovak Republic published Law No. 291/2025 on 21 October 2025 in the Official Gazette on 10 November 2025, implementing Council Directive (EU) 2025/872 of 14 April 2025 (DAC9). DAC9 introduces rules that allow the central filing of the Top-up
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Netherlands: Government proposes aligned DAC9, DAC8 implementation date
The Netherlands government has submitted an amendment aligning the effective date of the DAC9 implementation bill (Directive 2025/872) with the bill introducing DAC8 (Directive 2023/2226). The updated amendment was released on the Ministry of
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Australia: ATO clarifies hybrid mismatch rules, updates guidance reflecting adoption of Pillar 2 framework
The Australian Taxation Office (ATO) has revised its guidance on the Hybrid Mismatch rules, clarifying how the provisions operate and when they are triggered on 4 November 2025. The key updates relate to Australia’s adoption of the Pillar Two
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Italy: MoF issues decree on global minimum tax return, payments
Italy’s revenue agency has announced, on 10 November 2025, that the Ministry of Finance’s Decree of 7 November 2025 has been issued, establishing the filing and payment requirements for the global minimum tax, including the Income Inclusion Rule
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Poland: MoF consults draft GloBE information return form
Poland’s Ministry of Finance (MoF) has initiated a public consultation on 5 November 2025 regarding the draft of the GloBE Information Return (GIR) form, developed under Article 133 of the Act of 6 November 2024 on the Top-Up Taxation of
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Czech Republic: New government plans corporate tax cut, key economic reforms
The Czech Republic's new incoming government has unveiled its draft program, pledging not to increase taxes. The draft program declaration of the Czech Republic government, slated for November 2025, outlines an ambitious plan for securing sound
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Canada: DoF releases 2025 budget, includes corporate tax and transfer pricing measures
Canada’s Department of Finance released the details of the Budget 2025 on 4 November 2025. The main tax measures of the budget are as follows: Business Income Tax Measures Immediate Expensing for Manufacturing and Processing
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Singapore: Government presents second reading opening remarks on the Finance (Income Taxes) Bill
Singapore’s Senior Minister of State for Finance Jeffrey Siow has presented second reading opening remarks on the Finance (Income Taxes) Bill at the parliament on 6 November 2025. The Bill serves two main purposes: First, it updates the
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Japan: NTA updates Pillar 2 tax Q&A guidance
Japan’s National Tax Agency (NTA) updated its Q&A guidance, in October 2025, on the Pillar 2 global minimum tax for fiscal years starting 1 April 2024. The guidance provides a detailed Question and Answer (Q&A) framework on the
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Italy: MoF issues guidance for filling global minimum tax information return form
Italy's revenue agency has announced that the Ministry of Finance has issued guidelines for completing the Pillar 2 GloBE Information Return (GIR) model form (Comunicazione Rilevante on 3 November 2025. This follows the approval of the form under
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EU: CJEU rejects Dutch firm’s appeal contesting the global minimum tax directive
The Court of Justice of the European Union (CJEU) rejected an appeal filed by Dutch multinational enterprise group Fugro NV on 30 October 2025, upholding the EU General Court’s earlier decision to dismiss the company's challenge to the EU Global
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Kenya: KRA consults on draft income tax regulations for advance pricing agreement, minimum top-up tax for 2025
The Kenya Revenue Authority (KRA) released two draft regulations for public consultation, covering its global minimum tax regime and advance pricing agreement procedures for 2025, on 3 November 2025. In compliance with the Statutory Instruments
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South Africa: SARS revises timeline for GloBE registration, notification
The South African Revenue Service (SARS) has rescheduled the launch of the GloBE registration and notification functionality on e-Filing from December 2025 to 16 March 2026. This adjustment ensures system quality and compliance with international
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Vietnam: MoF releases pillar 2 tax procedures, forms
Vietnam’s Ministry of Finance has issued Decision 3563/QD-BTC introducing new tax administrative procedures and forms on 21 October 2025, under the management of the Tax Management Department of Large Enterprises, in line with Decree
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