Poland gazettes notice identifying 44 jurisdictions with QIIR, 49 with QDMTT under GloBE rules
Poland has issued a notice identifying jurisdictions, other than Poland, that have introduced a qualified income inclusion rule (QIIR) or a qualified domestic minimum top-up tax (QDMTT), or that satisfy the QDMTT safe harbour conditions. The notice,
See MoreNorway consults on updates to non-cooperative tax jurisdiction lists following EU changes
Norway's Ministry of Finance opened a public consultation on 3 June 2026 regarding amendments to Regulations No. 1379 (1 July 2025) on non-cooperative jurisdictions for tax purposes. The consultation period closes on 17 June 2026, providing
See MoreBrazil rules US LLCs owned by Brazilian residents are privileged tax regimes
Brazil’s tax authority, the Federal Revenue Service (RFB) has determined that US Limited Liability Companies owned by Brazilian tax residents qualify as privileged tax regimes, triggering automatic annual taxation requirements. The decision came
See MoreCyprus tax authority publishes low-tax jurisdiction list for defensive tax measures
Cyprus Tax Department issued Circular 1/2026 on 9 April 2026, which formally establishes the list of jurisdictions classified as low-tax jurisdictions for the 2026 tax year. This circular is a critical component of Cyprus's implementation of
See MoreCyprus mandates new documentation requirements for cross-border payments to low-tax jurisdictions
Cyprus' Council of Ministers introduced three decrees (K.D.P. 131/2026, 132/2026, and 133/2026) to combat tax abuse involving payments to low-tax and non-cooperative jurisdictions on 13 March 2026. These measures, effective from 1 January 2026,
See MorePoland publishes tax non-cooperative jurisdictions present in EU list, absent from own
Poland’s Ministry of Finance and Economy issued an official notice on 10 March 2026 regarding countries and territories identified by the European Union as tax non-cooperative jurisdictions that are not included in Poland's domestic harmful tax
See MoreIndonesia: 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
See MoreEU 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,
See MoreChile: SII revises UAE’s status on its preferential tax regimes listÂ
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
See MoreKazakhstan 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
See MoreNorway 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,
See MoreDenmark: 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
See MoreChile 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
See MoreNetherlands: 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
See More