Turkey introduces nuclear energy tax exemptions, establishes vehicle excise floors
Turkey has enacted Law No. 7590, introducing several tax measures, including reforms to the special consumption tax (SCT) on motor vehicles, new tax incentives for the nuclear energy sector, and an extension of employment support measures. The law
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New Zealand tightens stance in updated TP guidance, introduces thin capitalisation infrastructure exemption
New Zealand’s Inland Revenue (IR) has issued updated guidance on Transfer Pricing Documentation and Thin Capitalisation Rules on 31 March 2026, replacing earlier versions from 2025 and 2021. The transfer pricing (TP) documentation guidance
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Australia: ATO consults on thin capitalisation compliance, risk-weighted asset allocation for foreign bank branches
The Australian Taxation Office has opened a public consultation on Draft Practical Compliance Guideline PCG 2026/D1, covering thin capitalisation and the allocation of risk-weighted assets to Australian branches of foreign banks. This
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Australia consults Board of Taxation’s review of thin capitalisation amendments
The Australian Board of Taxation released a consultation guide marking the beginning of a formal statutory review of recent reforms to the nation's thin capitalisation rules in March 2026. This consultation guide outlines an independent statutory
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Korea (Rep.) introduces transfer pricing reforms, Pillar Two rollout
Korea (Rep.) has published Presidential Decree No. 36128, partially amending the enforcement Decree of the International Tax Adjustment Act, in the Official Gazette on 27 February 2026. The Decree introduces sweeping updates to its international tax
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Australia to consult thin capitalisation reforms
Australia’s government has asked the Board of Taxation to independently review the recent changes to Australia’s thin capitalisation rules. These changes were introduced in Schedule 2 of the Treasury Laws Amendment (Making Multinationals Pay
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Brazil: RFB updates rules on credit losses, interest on equity
Brazil’s tax authority, the Federal Revenue Service (RFB) announced that it updated Normative Instruction RFB No. 1,700/2017 on 4 December 2025 to clarify the tax treatment of credit losses and interest on equity (JCP). The changes respond to
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Ireland: Irish Revenue revises guidance on tax treatment of debt issuance costs, covering interest cap fees
Irish Revenue has issued eBrief No. 217/25 on 25 November 2025, updating the Tax and Duty Manual (TDM) Part 04-06-21 on the tax treatment of debt issuance costs, including interest cap fees. The update incorporates guidance on interest cap fees,
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Bolivia: Chamber of Deputies considers 2026 state budget proposal
Bolivia’s Executive Branch has submitted the 2026 General Budget Bill to the Chamber of Deputies on 31 October 2025, outlining a series of targeted tax incentives to reduce the cost of public debt operations conducted in foreign capital
See MoreAustralia: 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
See MoreAustralia: ATO issues final ruling on thin capitalisation third-party debt rules
The TPDT, introduced by the 2024 Treasury Laws Amendment, replaces the arm's length debt test for general investors and financial entities with a simpler, more streamlined method. The Australian Taxation Office (ATO) has issued Taxation Ruling TR
See MoreAustralia: ATO releases official form to revoke thin capitalisation test elections
The form enables eligible entities to revoke a previously made thin capitalisation test choice, including the group ratio or third-party debt tests. The Australian Taxation Office (ATO) released the official form for revoking thin capitalisation
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Philippines introduces tax reforms targeting large-scale metallic mining activities
Republic Act No. 12253 takes effect on 20 September 2025, affecting large-scale metallic mining contractors 150 days later, with implementing rules to be issued within 90 days. The Philippines has published Republic Act No. 12253, an Act
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Chile: SII clarifies thin capitalisation exemption for financial entities
The tax administration clarified that to be exempt from thin capitalisation rules, an entity must engage solely in financial activities (with limited complementary activities), certain assets are excluded from the 90% threshold, and the commercial
See MoreAustralia: 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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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
See MoreAustralia: 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
See MoreNew 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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