Ukraine suspends CFC reporting fines during martial law
Ukraine’s president, Volodymyr Zelensky has signed Law No. 9319 on 25 December 2024 which postpones a new military tax hike for small businesses and individual taxpayers until 1 January 2025. Under this law, Ukrainian residents will not be fined
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Netherlands updates tax penalty rules
The Netherlands State Secretary for Finance has published Decree No. 2024-15074 of 18 December 2024 in the Official Gazette on 31 December 2024, outlining various tax penalties which include several penalty increases effective from 1 January
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UN: General Assembly approves negotiations for global tax cooperation framework
The UN General Assembly adopted a resolution establishing the terms of reference for a United Nations Framework Convention on International Tax Cooperation. The resolution passed with 119 countries voting in favor, 9 opposed, and 43
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Poland sets base and margin rates for transfer pricing
Poland has published Notice No. 1105 in the Official Gazette on 21 December 2024, setting the base interest rates and margin interest rates for transfer pricing in individual and corporate income taxes. The regulation establishes base interest
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Germany: Federal Council approves revised Bill for tax law advancements, income tax adjustments
The German Federal Council (Bundesrat) approved the updated version of the bill aimed at further developing tax law and adjusting the income tax brackets on 20 December 2024. It will enter into force after publication in the Official Gazette. The
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Russia: MoF clarifies loss carry-forward rules for CFCs redomiciled as international companies
The Russian Ministry of Finance (MoF) clarified in Guidance Letter No. 03-12-11/2/107192, published on 9 December 2024 that, under certain conditions, losses can be carried forward by a controlled foreign company (CFC) registered in Russia and
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Thailand introduces Pillar Two top-up tax for MNEs
Thailand's Revenue Department has announced the publication of the Emergency Decree on Top-up Tax B.E. 2567 (2024) in the Official Gazette on 26 December 2024,introducing the implementation of a domestic minimum top-up tax for MNE groups with a
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Ireland: Revenue issues guidance on new VAT scheme for SMEs
Irish Revenue issued eBrief No. 315/24 on 13 December 2024 which outlines the European Union (EU) Value Added Tax (VAT) scheme for small and medium-sized enterprises (SMEs) effective from 1 January 2025. Currently, Member States can set their
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Peru raises tax unit value (Unidad Impositiva Tributaria) for 2025
Peru has increased the value of its Tax Unit (Unidad Impositiva Tributaria - UIT) for the 2025 fiscal year. The value will rise from PEN 5,150 to PEN 5,350, as outlined in Supreme Decree No. 260-2024-EF. This announcement was published on 17
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Singapore: IRAS publishes new guidance on MNE top-up tax, domestic top-up tax
The Inland Revenue Authority of Singapore (IRAS) has released a new e-Tax Guide on the Multinational Enterprise (MNE) Top-up Tax (MTT) and Domestic Top-up Tax (DTT) on 31 December 2024. This e-Tax guide sets out the key parameters of the MTT and
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Oman introduces Domestic Minimum Top-Up Tax for MNEs
The Oman Tax Authority has confirmed that a Royal Decree has been issued which implements a domestic minimum top-up tax, with a minimum effective tax rate of 15%, for multinational enterprise (MNE) groups in Oman, provided that these groups
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Kuwait introduces supplementary domestic minimum top-up tax for MNEs
Kuwait's Ministry of Finance announced on X that a supplementary domestic minimum top-up tax (DMTT) for large multinational enterprises (MNEs) has been introduced through Decree No. (157) of 2024 on 30 December 2024. The Decree is designed to
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Italy issues decree on Pillar Two rules, deferred tax attributes on transition
Italy’s Ministry of Economy and Finance has published the Ministerial Decree of 20 December 2024 in the Official Gazette No. 304 of 30 December 2024. The Decree outlines additional implementation rules for the top-up tax introduced under
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Norway publishes overview of tax changes for 2025
Norway’s government has released an overview outlining key tax changes which took effect on 1 January 2025. Some of the main changes include: Natural resource tax for hydropower The natural resource tax for hydropower plants has been
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Brazil: Revenue authority publishes updated guidance on commodities transfer pricing
Brazil’s revenue authority (Receita Federal) has issued new guidelines for Normative Instruction RFB No. 2246 of 30 December 2024, outlining rules for companies regarding the management of transfer pricing for transactions that involve commodities
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Lithuania gazettes 2025-27 budget, increases tax-exempt income threshold
Lithuania has published its budget plan for the three-year period from 2025 to 2027 in the official gazette on 19 December 2024. Key changes include an increase in the tax-exempt income threshold for 2025. Even though the budget for the next
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Turkey extends income tax incentives for tech, R&D employees
Turkey has announced an extension of income tax withholding incentives for employees in technology development zones and R&D or design centers. According to Presidential Decision No. 9368 on 27 December 2024, employees working outside these
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Saudi Arabia: ZATCA announces criteria for 19th wave of e-invoicing integration
The Saudi Arabian Zakat, Tax, and Customs Authority (ZATCA) has announced the eligibility criteria for Group 19 taxpayers in the integration phase of e-invoicing on 27 December 2024. The 19th phase will include all taxpayers whose revenues
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