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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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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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
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Cyprus imposes new defensive tax rules on payments to low-tax and non-cooperative jurisdictions
Cyprus has published Laws No. 47(I)/2025 and No. 48(I)/2025 in the Official Gazette on 16 April 2025. These laws introduce updated defensive measures on outbound payments of dividends, interest, and royalties to non-cooperative or low-tax
See MoreTaiwan announces the amendments to the tax treaty rules and PE rules
On 12 August 2021, Taiwan’s Ministry of Finance has announced the amendments to the “Regulations Governing Application of Agreements for the Avoidance of Double Taxation with Respect to Taxes on Income”. The amended regulations have come into
See MoreUS: IRS releases draft instructions Schedules K-2 and K-3 for international tax reporting
On 30 June 2021, the Treasury and the IRS released early draft instructions for the Schedules K-2 and K-3 for Forms 1065, 1120-S, and 8865 for tax year 2021 (filing season 2022). The early release drafts of the instructions provide a preview
See MoreOECD: Tax issues for cross border workers during the COVID-19 crisis
On 7 April 2020 the OECD published on its website guidance on tax issues relating to cross-border workers during the crisis. As a result of travel restrictions and quarantine requirements many cross-border workers cannot go to the country where
See MoreMauritius: Signing of MOU with South Africa
South Africa and Mauritius have signed a memorandum of understanding (MOU) on 22 May 2015. Following the signature of the MOU the revised Double Taxation Agreement between the two countries is expected to become effective from 1 January 2016. To
See MoreHong Kong: IRD Releases Revised Forms To Apply For Resident Status For Tax Treaties
The Inland Revenue Board of Hong Kong on January 29 released revised forms for companies, partnership, trusts, and other entities to apply for a certificate of resident status for purposes of claiming tax treaty benefits. With effect from 1 February
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