OECD adds Guernsey to list of qualified Pillar Two jurisdictions
The OECD issued an update on 31 March 2025, in which Guernsey has been added as a jurisdiction with a qualified income inclusion rule (IIR), domestic minimum top-up tax rule (QDMTT), and meeting QDMTT safe harbor standards. This should prevent
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Switzerland: Tax Administration clarifies tax treatment of permanent establishments under Pillar two GloBE rules, Swiss minimum tax
The Swiss Federal Tax Administration published Communication-023-E-2025-f on 18 March 2025, addressing the tax treatment of constituent entities qualifying as permanent establishments under the GloBE rules and the Swiss Minimum Tax Ordinance. The
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Poland excludes some EU non-cooperative jurisdictions from harmful tax competition list
Poland’s Minister of Finance issued a notice on 8 March 2025 identifying countries and territories listed on the EU's register of non-cooperative jurisdictions but not on Poland's list of nations engaging in harmful tax competition for individual
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Chile updates list of preferential tax regimes
Chile's Internal Revenue Service (SII) has issued Resolution No. 30 of 6 March 2025 with an updated list of territories and jurisdictions with preferential tax regimes. The list reflects the new rules introduced by the Law on Compliance with Tax
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EU: Council reviews list of non-cooperative tax jurisdictions
The European Economic and Financial Affairs Council, in a meeting on 18 February 2025, confirmed the EU list of non-cooperative jurisdictions for tax purposes without changes. During the meeting, the Council reviewed the EU list of
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China revises tax residency certificate rules
China's State Administration of Taxation has released Announcement No. 4 of 2025 outlining revised rules and procedures for obtaining a "Certificate of Tax Residency" for enterprises and individuals. The Announcement No. 4 of 2025 will take
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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
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Hong Kong publishes draft guidance on proposed company re-domiciliation regime
The Hong Kong Inland Revenue Department has released draft guidance on the proposed company re-domiciliation regime introduced under the Companies (Amendment) (No. 2) Bill 2024 on 20 December 2024. It is pending approval in the Legislative
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Italy clarifies permanent establishment exemption for investment management
Italy’s tax authorities released Circular No. 23/E on 19 November 2024, outlining the guidelines for the permanent establishment investment management exemption introduced in the 2023 Budget Law. One of the key provisions in the 2024 Budget Law
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Italy publishes updated guidance on amended tax residence rules for individuals, companies
Italy’s Revenue Agency released the Circular No. 20/E, offering guidance on tax residency for individuals, companies, and other entities on 4 November 2024. The guidance follows the revisions introduced by Legislative Decree No. 209 of 27
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Russia clarifies transfer pricing rules for foreign entities with permanent establishments
Russia’s Ministry of Finance (MOF) has issued a guidance letter No. 03-12-12/1/59174 clarifying the transfer pricing obligations for controlled transactions involving foreign legal entities operating through permanent establishments (PEs) in
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OECD: Tax Arbitrage Through Closely Held Businesses
On 7 October 2024 the OECD published a taxation working paper with the title Tax arbitrage through closely held businesses: Implications for OECD tax systems, written by Tom Zawisza, Sarah Perret, Pierce O’Reilly and Antonia Ramm. The working
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India: Access to foreign booking systems by domestic entities does not establish a taxable presence
The Delhi Bench of India's Income-tax Appellate Tribunal (ITAT) on 9 February, 2024, delivered a landmark decision asserting that granting domestic travel agents access to a computer reservation system located abroad does not establish a fixed place
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Comparative Tax Revenue Effects of Amount A and Digital Service Tax Regimes
As authors of several studies that estimate the tax revenue impact of Amount A for various countries and compare the Amount A impact with revenues from a model digital service tax (DST) regime, we observed certain patterns that hold true for various
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Belarus introduces new 25% tax rate for foreign organizations with permanent establishments (PEs)
On 20 March 2024, the Belarusian Ministry of Taxes and Duties released Letter No. 4-2-21/00850 on March 20, 2024, addressing the tax obligations of foreign entities with permanent establishments (PEs) conducting business in the Republic of Belarus.
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UN: ECOSOC Special Meeting on International Cooperation in Tax Matters
On 18 March 2024 the ECOSOC Special Meeting on International Cooperation in Tax Matters took place against the urgent background of the collective action required to put the Sustainable Development Goals (SDGs) back on track, strengthen institutions
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Germany: MoF issues updated guidelines on permanent establishment criteria and remote work
On 5 February 2024, the German Ministry of Finance (MoF) issued revised instructions concerning the criteria for a permanent establishment (PE), as commonly outlined in section 12 of the General Tax Code for the purposes of domestic tax law.
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Slovenia enacts adjustments to permanent establishment and interest limitation regulations
On 9 February 2024, Slovenia officially released the Act amending the Corporate Income Tax Act (ZDDPO-2T) in the Official Gazette. The provisions outlined in the legislation encompass: Preventing PE status misuse: New rules limit on strategies
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