France simplifies EU public CbC reporting rules
France adopted new rules on 28 December 2025 to streamline compliance with the EU public CbC reporting directive (Directive (EU) 2021/2101), fully aligning national law with EU requirements and implementing the multiple reporting exemption. The
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Switzerland updates CbC reporting list
Switzerland has updated its list of jurisdictions for the automatic exchange of Country-by-Country (CbC) reports under the Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports (CbC MCAA). Decision No. RO
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Luxembourg: Government Council updates CbC reporting jurisdiction list
Luxembourg’s Government Council chaired by Prime Minister Luc Frieden, met on 16 January 2026 to review international, European, economic, social and financial policy matters and to adopt a series of legislative and regulatory measures. Among
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Australia: ATO publishes final guidance on public CBC reporting exemptions
The Australian Taxation Office published Practice Statement Law Administration PS LA 2025/2, Public country-by-country reporting exemptions, on 8 December 2025. The statement sets out the administrative approach to the Commissioner's discretion for
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Cyprus: Tax department issues guidance on bilateral CbC reporting agreement with the US
The Cyprus Tax Department, in an announcement on 25 November 2025, clarified that all legal entities and their representatives are covered by the bilateral Competent Authority Agreement for the exchange of Country-by-Country (CbC) reports between
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Denmark expands CbC reporting requirements
Denmark expanded CbC reporting, requiring full entity details from 1 January 2028. The Danish government has published Executive Order No. 1157 on 9 September 2025, broadening the scope of information that multinational enterprise (MNE) groups
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Russia: FTS consults on revising jurisdiction list for CbC report exchange
The deadline for submitting comments is 17 September 2025. Russia’s tax authority, the Federal Tax Service (FTS), has opened a consultation regarding proposed changes to the list of jurisdictions participating in the automatic exchange of
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Kazakhstan adopts transfer pricing law amendments, emphasises ‘substance over form
Kazakhstan’s President signed amendments to transfer pricing regulations on 18 July 2025, introducing new rules effective 1 January 2026 that emphasize substance over form, revise reporting thresholds, define key financial terms, and tighten
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Kazakhstan consults transfer pricing law amendments
The amendment proposes using the official exchange rate to calculate the CbC reporting threshold under transfer pricing rules. Kazakhstan’s Ministry of Finance has initiated a public consultation regarding the draft order proposing changes to
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Denmark, Faroe Islands sign agreement for automatic exchange of tax information
The Danish Tax Agency announced on 8 July 2025 that it signed an agreement with the Faroe Islands to automatically exchange country-by-country tax reports. The Danish Tax Agency announced on 8 July 2025, it had signed a Competent Authority
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Ukraine mandates 2024 CbC reports from MNEs headquartered in US, Canada, Israel
The automatic exchange of reports with these countries have not yet fully worked as of the end of 2024. The State Tax Service of Ukraine announced that constituent entities in Ukraine belonging to multinational enterprise (MNE) groups
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Singapore adds Cameroon to CbCR exchange list for FY2024
The update takes effect for financial years (FY) starting from 2024. The Inland Revenue Authority of Singapore (IRAS) has updated its Country-by-Country Reporting (CbCR) guidance as of 20 June 2025, expanding the list of jurisdictions eligible
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Sweden clarifies group contributions in CbC reporting
Group contributions should be excluded from profit or loss calculations in Country-by-Country (CbC) reporting. Sweden’s tax agency (Skatteverket) has issued Position Statement No. 8-174683-2025 on 17 June 2025, clarifying its stance on group
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Cape Verde joins OECD agreement on exchange of CbC reports
Cape Verde has signed the OECD Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA) on 9 April 2025. Under BEPS Action 13, all large multinational enterprises (MNEs) are required to prepare a
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Ukraine issues guidance on CbC reporting for US parent multinationals
The State Tax Service of Ukraine issued a guidance letter (No. 1308/IPK/99-00-21-02-03 IPK) on 12 March 2025 regarding the requirement for Ukrainian entities to submit a Country-by-Country (CbC) report on behalf of their US-based parent
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Mongolia joins Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports
Mongolia joined the Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports (2016) (CbC MCAA) on 6 March 2025. The Country-by-Country Multilateral Competent Authority Agreement (CbC MCAA) is grounded in
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Serbia joins Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports
Serbia joined the Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports (2016) (CbC MCAA) on 4 March 2025. The Country-by-Country Multilateral Competent Authority Agreement (CbC MCAA) is grounded in
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Germany updates CbC Report exchange list, adds four new jurisdictions
The German Official Gazette (Bundesgesetzblatt) No. 64 published the Seventh Regulation Amending the Country-by-Country (CbC) Report Extension Regulation on 11 March 2025. This update revises the list of jurisdictions participating in the
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