Netherlands issues tax guidance on permanent establishment requirements under Minimum Tax Act
The Dutch tax authorities issued guidance clarifying when a permanent establishment (PE) qualifies under the Minimum Tax Act 2024 (WMB 2024) on 26 February 2026, addressing critical questions about the Netherlands' implementation of the global
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Indonesia: DJP establishes specific criteria for identifying domestic, foreign tax subjects
Indonesia's Directorate General of Taxation (DJP) issued Regulation PER-23/PJ/2025, which was enacted on 9 December 2025, establishing the specific criteria for identifying domestic and foreign tax subjects. It defines domestic subjects as
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Germany publishes draft permanent establishment guidelines
The German Federal Ministry of Finance has released a draft of its revised guidelines on permanent establishments (PEs) in domestic and international tax law. These guidelines are intended to replace the previous version issued in December
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EU maintains current list of non-cooperative tax jurisdictions
ECOFIN confirmed the EU’s list of 11 non-cooperative tax jurisdictions, leaving it unchanged. The European Economic and Financial Affairs Council (ECOFIN) reconfirmed the EU list of non-cooperative tax jurisdictions on 10 October 2025,
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Chile: SII revises UAE’s status on its preferential tax regimes list
This resolution repeals Resolution Ex. SII No. 61-2025, which had set 1 June 2023 as the removal date, and confirms that the UAE is not considered to have a preferential tax regime under the Income Tax Law (LIR). Chile’s tax administration
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Kazakhstan consults on preferential tax jurisdictions list
The deadline for submitting comments is 6 August 2025. Kazakhstan's Ministry of Finance initiated a public consultation on 22 July 2025 regarding a draft order for jurisdictions with preferential tax regimes. This list impacts tax measures for
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Finland: MoF consults on OECD-based PE profit attribution
The deadline to submit comments is 30 June 2025. Finland’s Ministry of Finance has opened a public consultation to amend three key tax laws: the Income Tax Act, the Act on Taxation of Business Income, and the Act on the Elimination of
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Norway issues list of non-cooperative tax jurisdictions
Norway's Ministry of Finance adopted a regulation listing non-cooperative tax jurisdictions to align with EU and EEA obligations. Norway’s Ministry of Finance adopted the Regulation on Non-Cooperative Jurisdictions for Tax Purposes, which
See MoreFinland: President approves extension of residency exemption for UCITS and AIF funds
The law extends the corporate residency exception for certain investment funds until 31 December 2026. Finland’s President ratified a law on 27 June 2025 extending the exception to corporate residency rules for certain investment funds until 31
See MoreChile clarifies conditions for indirect asset disposal tax exemption
The tax authority’s clarification involves addressing the tax implications of an Australian business group's indirect disposal of underlying assets in Chile. Chile’s tax authority (SII) issued Letter Ruling No. 1154 on 19 June 2025,
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Australia: ATO revises corporate tax residency guidelines
The ATO updated its corporate tax residency guidelines on 11 June 2025, clarifying the central management and control (CMC) test The Australian Taxation Office (ATO) updated its corporate tax residency guidelines in PCG 2018/9 on 11 June 2025,
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Hong Kong passes law allowing company re-domiciliation
The inward re-domiciliation regime in Hong Kong was enacted on 23 May 2025, allowing non-Hong Kong companies to re-domicile while keeping their legal identity and business continuity. The Hong Kong company inward re-domiciliation regime became
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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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Chile confirms end date for Costa Rica’s preferential tax regime status
Chile’s tax Administration (SII) confirmed that Costa Rica is not considered a preferential tax regime under the Income Tax Law. Chile’s tax authority (SII) issued Letter Ruling No. 1007 on 22 May 2025 regarding when Costa Rica ceased to be
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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
See MoreNorway consults proposed list of non-cooperative tax jurisdictions
Norway’s Ministry of Finance opened a public consultation on a proposed list of jurisdictions deemed non-cooperative for tax purposes on 14 May 2025. The establishment of this list is part of the Ministry's work to implement EEA Joint Committee
See MoreHong Kong: Government approves new company re-domiciliation regime
The Hong Kong Government has approved the Companies (Amendment) (No.2) Bill 2024 on 14 May 2025, which introduces a new company re-domiciliation regime. Under the company re-domiciliation regime, non-Hong Kong-incorporated companies which fulfil
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Italy: Council of Ministers approves draft decree on local taxes and fiscal federalism
Italy’s Council of Ministers has approved a draft Legislative Decree on 9 May 2025, introducing measures on local taxes and regional fiscal federalism as part of a tax reform. The Decree introduces greater fiscal autonomy for territorial
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