Kazakhstan updates CbC notification form, mandates e-filing
Kazakhstan has revised the MNE group participation notification or country-by-country (CbC) notification form through Order No. 84 of 24 February 2025. The Order No. 84 amends Order No. 178 of 14 February 2018, which includes adjustments to the
See More
OECD updates signatories list for MCAA-CbC as of April 2025
The Organisation for Economic Cooperation and Development (OECD) released an updated list of signatories, along with their signing dates, for the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) Reports
See More
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
See More
Switzerland updates MCAA-CbC participation list, adds Antigua and Barbuda, Serbia
The Swiss Official Gazette published Decision No. RO 2025 243 on 11 April 2025 which updates the list of countries participating in the Multilateral Competent Authority Agreement (MCAA) for the exchange of country-by-country reports (CbCR). The
See More
Germany: Ministry of Finance clarifies application of CbC reporting for transparent partnerships
Germany’s Federal Ministry of Finance published a letter on 3 April 2025 addressing how Country-by-Country (CbC) reporting applies to tax-transparent partnerships, including their treatment under the Transitional CbCR Safe Harbour for Pillar
See More
Germany mandates transaction matrix transfer pricing documentation requirement
Germany’s Ministry of Finance released a decree outlining the requirements for the “transaction matrix,” a new component of transfer pricing documentation under section 90(3) of the Fiscal Code (AO) on 2 April 2024. The transaction matrix
See More
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
See More
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
See More
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
See More
Australia: ATO updates country-by-country reporting rules from 2025
The Australian Taxation Office (ATO) introduced changes to Country-by-Country reporting (CbCR) from 1 January 2025, which requires Version 4 of the local file/master file schema for reporting periods starting on or after 1 January
See More
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
See More
Australia: ATO issues guidance on public CbCR exemptions
The Australian Taxation Office (ATO) has updated its list of topics under review, including exemption discretions for public country-by-country reporting (CbCR). Purpose This draft Practice Statement will outline the Commissioner’s approach
See More
Singapore: IRAS adds Dominican Republic to CbC reporting exchange list
The Inland Revenue Authority of Singapore (IRAS) updated its Country-by-Country Reporting guidance page on 5 March 2025. The update includes a revised list of jurisdictions with which CbC reports (CbCR) can be automatically exchanged, adding
See More
OECD revises signatories list for MCAA-CbC as of February 2025
The Organization for Economic Cooperation and Development (OECD) has released an updated list of signatories to the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) Reports on 26 February 2025. The
See More
Israel clarifies CbC reporting rules for MNEs
The Israel Tax Authority (ITA) issued Income Tax Circular No. 1/2025 on 11 February 2025, which clarifies amendments to the Income Tax Ordinance. The amendments pertain to transfer pricing and country-by-country (CbC) reporting requirements. The
See More
Ukraine updates fines for certain transfer pricing reporting violations
The State Tax Service of Ukraine issued a notice on fines for specific transfer pricing reporting violations on 5 February 2025. A penalty of 100 subsistence minimums is imposed for not submitting the notification of participation in an
See More
OECD updates MCAA-CbC signatory list
The Organization for Economic Cooperation and Development (OECD) has released an updated list of signatories to the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) Reports on 10 February 2025. The
See More
Vietnam joins multilateral deal on CbC report exchange
The Organisation for Economic Co-operation and Development (OECD), in an update on 10 February 2025, has confirmed that Vietnam signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA) on 3
See More