Denmark: Parliament reviews bill L 23 to implement EU DAC9
The bill proposes amendments to Danish tax laws to align with EU rules on Top-up tax reporting under DAC9, due by 31 December 2025. Denmark’s parliament is reviewing draft Bill L 23 on 8 October 2025, which aims to implement Council Directive
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El Salvador: DGII introduces Form F-935 to report withholding taxes by foreign agents, individuals, entities
The notice instructs foreign agents to report all withholding taxes on the Form by the 15th of the month after the taxes were withheld. El Salvador’s tax administration (DGII) released a notice on 30 September 2025, introducing Form F-935 for
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Australia: ATO cautions of heavy penalties for global entities delaying TPAR submission
The ATO warns that Significant Global Entities (SGEs) that missed the 28 August TPAR deadline may face penalties for late lodgment. The Australian Taxation Office (ATO) announced on 8 October 2025 that Significant Global Entities (SGEs) may face
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Costa Rica: DGT extends October tax deadlines amid TRIBU-CR system transition
Resolution MH-DGT-RES-0047-2025 grants a one-time extension, moving the deadline for self-assessment tax returns and July–August 2025 information returns. Costa Rica’s tax administration (DGT) published Resolution No. MH-DGT-RES-0047-2025 in
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Kazakhstan: MoF approves new CFC reporting, taxation forms for 2026
Ministry of Finance introduced new forms for reporting and taxing Controlled Foreign Companies, effective 1 January 2026. Kazakhstan’s Ministry of Finance issued Order No. 536 on 25 September 2025, approving new forms for the reporting and
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Kazakhstan approves new rules for taxable income of second-tier banks
The new regulations are designed for calculating second-tier banks’ taxable income, effective 1 January 2026. Kazakhstan’s Ministry of Finance and National Bank have jointly approved new rules for determining taxable income from banking
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Lithuania tax authority revises guidance to clarify corporate tax rates
From 2026, Lithuania will set the corporate income tax rate at 17% for local entities and PEs, apply a 10% flat tax to certain income of foreign entities without a PE, and allow small businesses under EUR 300,000 annual revenue to pay 0% tax for the
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Luxembourg: MoF presents 2026 state budget to Chamber of Deputies, proposes fiscal measures to bolster innovation-driven investments
The 2026 budget focuses on strengthening its financial centre through tax reforms and tech investments, while expanding incentives and support measures for SMEs and start-ups to boost innovation and entrepreneurship. Luxembourg's Minister of
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Uruguay: Economy and Finance Minister proposes amendments to global minimum tax for 2025–29 budget bill
The 2025–29 Budget Bill proposes a new domestic minimum tax for large multinational groups from 2027. Uruguay’s Minister of Economy and Finance, Azucena María Arbeleche Perdomo, has introduced proposed changes to the global minimum tax
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Brazil updates Contribution on Net Profit rules, aligns with QDMTT under Pillar 2
Brazil updated CSLL rules to align with Pillar 2 QDMTT, retroactively effective from 1 January 2025. Brazil’s Federal Revenue Service (RFB) has issued Normative Instruction No. 2.282 on 2 October 2025, amending Normative Instruction No. 2.228
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Slovak Republic: MoF launches six-month tax amnesty period
The Finance Ministry unveils a six-month tax amnesty, excluding arrears settled before 2026. The Slovak Republic’s Ministry of Finance has outlined key dates for taxpayers planning to take advantage of the government’s “tax amnesty”
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Israel consults draft law on domestic top-up minimum tax draft
Ministry of Finance initiated a public consultation on draft legislation introducing a domestic top-up minimum tax, set to apply from 1 January 2026 to Israeli-resident entities in multinational groups with global revenues of EUR 750 million or
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US: IRS extends treaty benefits to reverse foreign hybrids subject to branch profits tax
The IRS Chief Counsel ruled that reverse foreign hybrids may qualify for reduced branch profits tax on dividend equivalent amounts attributable to treaty-eligible owners. The US Internal Revenue Service (IRS) Chief Counsel has determined that
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Belgium defines fixed financial asset requirement for participation exemption
The participation exemption applies to shareholders with at least 10% ownership or investments of EUR 2.5 million, provided the latter qualify as fixed financial assets. Belgium's Ministry of Finance has released Circular 2025/C/63 on 3 October
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Singapore: IRAS updates guidance on foreign tax credit claims
The updated guidance now features a revised eligibility flowchart and provides clearer time limits for claiming a Foreign Tax Credit (FTC). The Inland Revenue Authority of Singapore (IRAS) has released revised guidance on claiming a Foreign Tax
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Germany: MOF revises guidance on cross-border tax dispute resolution
The key changes in the guidance are aimed at simplifying terminology, clarifying the interaction of dispute resolution mechanisms, and providing expanded guidance for joint applications from partnerships and corporate groups. Germany’s Ministry
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Argentina: ARCA extends deadline for tax payment plan on incorrectly calculated losses
ARCA extends the deadline to 28 November 2025 for companies to join the payment plan for incorrectly calculated tax losses, allowing regularisation of debts with reduced down payments and up to 120 installments. The Argentine Revenue and Customs
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Ecuador: SRI updates e-filing rules for large taxpayers
Under this resolution, taxpayers must submit their declarations and pay their taxes at the same time, by the statutory due date. Ecuador’s tax authority (SRI) issued Resolution NAC-DGERCGC25-00000030 on 23 September 2025, updating the
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