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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Hong Kong: IRD extends filing deadline for 2024-25 profits tax returns
IRD extended the 2024/25 Profits Tax return filing deadline for ‘M’ code cases. The Hong Kong Inland Revenue Department (IRD) has announced on 2 October 2025 an extension for the lodgement of 2024/25 Profits Tax returns under the Block
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Turkey consults Pillar 2 global minimum tax implementation
The consultation is set to conclude on 27 October 2025. The Turkish Revenue Administration released a draft General Communiqué for public consultation, setting out the framework for implementing the Pillar 2 Global Minimum Tax (GMT) on 3 October
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UK: HMRC introduces tool to determine qualifying R&D activities for tax relief
The tool is designed to check R&D tax relief for eligible projects. The UK’s HM Revenue and Customs (HMRC) issued guidance on 30 September 2025 introducing an online tool designed to help taxpayers assess whether a project contains
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Australia: ATO issues final ruling on thin capitalisation third-party debt rules
The TPDT, introduced by the 2024 Treasury Laws Amendment, replaces the arm's length debt test for general investors and financial entities with a simpler, more streamlined method. The Australian Taxation Office (ATO) has issued Taxation Ruling TR
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Poland: Council of Ministers approve corporate tax increases for banks, cuts special bank levy
Starting in 2026, the standard corporate tax rate for banks will increase from 19% to 30% before dropping to 26% in 2027 and 23% from 2028 onward, while the reduced rate will rise from 9% to 20% in 2026 and then fall to 16% in 2027 and 13% in
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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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Canada: CRA simplifies tax adjustments through revised voluntary disclosures program
The VDP lets taxpayers voluntarily correct past tax errors for potential penalty and interest relief, but only for tax years overdue by at least one year. The Canada Revenue Agency (CRA) announced, on 10 September 2025, that it will update the
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EU: Commissioner Hoekstra addresses current state of Pillar 1, 2
The European Commissioner Wopke Hoekstra responded that the European Commission notes Canada’s decision to suspend its digital services tax but considers it a sovereign matter and will not comment further. The European Parliament released a
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US: IRS extends filing, payment deadlines for taxpayers impacted by ongoing conflict in Israel
IRS is providing separate but overlapping relief to taxpayers who may be unable to meet a tax-filing or tax-payment obligation, or may be unable to perform other time-sensitive tax-related actions. The US Internal Revenue Service (IRS) announced,
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