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 issues guidance on thin capitalisation rules, related provisions
The Australian Taxation Office (ATO) released guidance on 3 November 2024, outlining how the thin capitalisation rules interact with other provisions. The thin capitalisation rules limit the amount of debt deductions you can claim. Regard must
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US: IRS and Treasury Plan to Issue Guidance on Streamlined Approach to Baseline Distribution Activities
In the IRS and Treasury Priority Guidance Plan for 2024/25, issued on 3 October 2024, there is a plan for a new section 482 guidance project to provide guidance for taxpayers consistent with Amount B of Pillar One. The OECD Amount B Guidance
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Chile updates tax compliance law, introduces changes to GAAR, transfer pricing, and CFC
Chile's Internal Revenue Service (SII) has announced that the Law on Compliance with Tax Obligations (Law No. 21.713) has been published in the Official Gazette on 24 October 2024. General and Special Anti-Avoidance Rules changes The General
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UN: Resolution on Negotiating Committee for Framework Convention for International Tax Cooperation
On 14 October 2024 a Resolution was drafted by Nigeria on behalf of the Africa group at the UN, to adopt the terms of reference for the UN Framework Convention on International Tax Cooperation. The draft Resolution referred to the work of the Ad Hoc
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Latvia updates list of tax havens, removes Antigua and Barbuda
Latvia announced an updated list of low-tax and tax-free jurisdictions in the Official Gazette on 23 October 2024. This list, derived from the latest EU list of non-cooperative jurisdictions, notes the removal of Antigua and Barbuda, effective 1
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UN Tax Committee: Issues in Extractive Industries Taxation
On 15 October 2024 the UN Tax Committee discussed developments in their work on extractive industries taxation. The work of the relevant subcommittee has focused on the energy transition; the valuation of mining products for tax purposes; and tax
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UN Tax Committee: Transfer Pricing Issues
On 16 October 2024 the UN Tax Committee discussed transfer pricing issues. The transfer pricing subcommittee presented for approval a paper on dispute resolution addressing the implementation of advance pricing agreement (APA) programs. The
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Chile: Parliament passes tax compliance bill
Chile’s Chamber of Deputies have passed the Tax Compliance Bill (Proyecto de Ley de Cumplimiento de las Obligaciones Tributarias). Earlier, Chile’s Senate approved the Tax Compliance Bill on 24 September 2024 which included key changes to
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Ireland named amongst top 10 tax havens globally
According to the Tax Justice Network's latest ranking report published on 1 October 2024, Ireland has surpassed the Bahamas to become the ninth-largest tax haven in the world. A spokesperson for Ireland's Department of Finance has denied that the
See MoreChile passes tax compliance bill with income, VAT, transfer pricing measures
Chile’s Senate has approved the Tax Compliance Bill on 24 September 2024, which will be presented to the Lower House for final approval. The newly approved tax measures include modifications to the general anti-avoidance rule (GAAR), statute of
See MoreOECD: Report on Simplified Peer Review of Nigeria under BEPS Action 14
On 16 September 2024 the OECD published the simplified peer review report on Nigeria under Action 14 of the project on base erosion and profit shifting (BEPS). The report sets out the results of Stage 1 of the simplified peer review of the
See MoreOECD: Report on Simplified Peer Review of Costa Rica under BEPS Action 14
On 16 September 2024 the OECD published the simplified peer review report on Costa Rica under Action 14 of the project on base erosion and profit shifting (BEPS). Members of the OECD Inclusive Framework have committed to implementing the minimum
See MoreOECD: Report to the July Meeting of G20 Finance Ministers
On 25 July 2024 the OECD published the report prepared for the meeting of G20 Finance Ministers and Central Bank Governors held in Brazil from 25 to 26 July 2024. The report notes some recent developments in important areas of international tax
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OECD: Definition of qualifying jurisdictions for application of Amount B of Pillar One
On 17 June 2024 the OECD Inclusive Framework on BEPS released supplementary elements relating to the report of 19 February 2024 on Amount B of Pillar One. Under the streamlined and simplified approach under Amount B, a pricing matrix is used to
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UN: Ad Hoc Committee Discusses Issues for Early Protocols
Following an earlier Resolution on international tax cooperation and a report by the Secretary General setting out options going forward, UN Resolution 78/230 of 22 December 2023 established an ad hoc intergovernmental committee to draft terms of
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UN: Ad Hoc Committee on Framework Convention Discusses Substantive Elements
UN Resolution 78/230 of 22 December 2023 established an ad hoc intergovernmental committee to draft terms of reference for a UN framework convention on international tax cooperation. The first session of the ad hoc committee is being held between 26
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UN: Tax Committee Discusses Tax Issues in the Digitalised Economy
The 28th session of the UN Committee of Experts on International Cooperation in Tax Matters is being held from 19 to 22 March 2024. On 19 and 20 March 2024 the discussions included tax issues in the digital economy. Fast Track Instrument The
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