France issues rules for preparing, filing CbC reporting
France has published the Order of 3 July 2026 in the Official Gazette on 9 July 2026, establishing the rules for preparing and filing the profit tax information declaration (Public Country-by-Country Report) required under the French Commercial
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Vietnam gazettes decree updating transfer pricing rules
Vietnam has published Decree No. 255/2026/ND-CP, issued on 30 June 2026, introducing a new framework for tax administration of enterprises engaged in related-party transactions. The Decree sets out the principles, methods and compliance requirements
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India: CBDT rolls out 2026 income tax rules with expanded transfer pricing framework
India’s Central Board of Direct Taxes (CBDT) issued Notification No. 22/2026 on 20 March 2026 under the Income Tax Act, 2025, introducing the Income Tax Rules, 2026. The rules provide a comprehensive framework for income tax administration,
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UK: HMRC updates CbC reporting guidance
UK’s His Majesty's Revenue and Customs (HMRC) updated its country-by-country reporting (CbCR) guidance on 17 March 2026, clarifying which entities must report, how to register and submit reports, and the process for agents seeking
See MoreVietnam: MoF drafting new transfer pricing, taxpayer obligations, CbC reporting rules
The Vietnamese Ministry of Finance (MoF) is preparing a draft Decree on tax administration for related-party transactions of enterprises with affiliated relationships, in line with the Law on Tax Administration No. 108/2025/QH15. The new
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Australia: ATO releases public country-by-country reporting compliance guidance
The Australian Taxation Office (ATO) has released instructions to complete the public country-by-country report on 3 March 2026. The instructions include: Public CBC report overview Overview of Public CBC report instructions and publishing
See MoreFrance 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
See MoreKazakhstan 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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