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
See More
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,
See More
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
See More
Belarus updates tax guidance for foreign permanent establishments
The Belarus Ministry of Taxes and Duties has published Letter No. 4-2-21/01461 of 18 April 2025 on taxing foreign organisations operating in Belarus through a permanent establishment. The letter replaces Letter No. 4-2-21/00850 of 20 March 2024, and
See More
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
See More
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
See More
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
See More
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
See More
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
See More
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.
See More
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.
See More
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
See More
Saudi Arabia: ZATCA releases drafts of new income tax and tax procedural laws for public consultation
On 25 October 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued drafts of a new Income Tax Law and Zakat and Tax Procedures Law for public consultation. The public consultation period for comments on the drafts is open until 25
See More
Slovenia: MoF issues a draft bill to amend the corporate income tax law
On 17 October 2023, the Slovenian Ministry of Finance (MoF) issued a draft bill to amend the corporate income tax law. Once adopted by the Slovenian parliament the amendments will apply from 1 January 2024. The following amendments are
See More
Egypt publishes income tax amendment law
On 15 June 2023, the Egyptian Tax Authority published Law No. 30 of 2023 in the Official Gazette amending some provisions of the Income Tax Law No. 91 of 2005. The Law entered into force on 16 June 2023. The key amendments to the Income Tax Law are
See More
Pakistan: Government passes Finance Act 2023
On 26 June 2023, the government of Pakistan published the Finance Act 2023, which included changes to some of the measures that were proposed in the Budget announcement on 9 June 2023. Some notable changes, in addition to those outlined in the
See More
Saudi Arabia: ZATC issues a Circular on the taxation of PE in the context of DTA
On 17 May 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued Circular No. 2303001 regarding the taxation of Permanent Establishments (PEs) in the context of Double Taxation Agreements (DTA). The Circular serves to provide
See More
Belarus updates guidance on the taxation of foreign organizations operating through a PE
On 10 March 2023, the Ministry of Taxes and Duties of Belarus issued Guidance Letter No. No.4-2-21/00759 to clarify the taxation of foreign organizations operating in the territory of the Republic of Belarus through permanent establishments (PEs).
See More