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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Australia: ATO consults public CbC reporting exemptions
Comments on this draft PS LA are due by 5 September 2025. The Australian Taxation Office (ATO) has initiated a public consultation on the Draft Practice Statement Law Administration (PS LA 2025 /D1) on 3 July 2025. This draft sets out the
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US, Dominican Republic CbC reporting agreement now in force
The US–Dominican Republic competent authority arrangement for automatic exchange of Country-by-Country reports became operative on 5 May 2025, with exchanges to begin by 5 August 2025. The competent authority arrangement between the US and the
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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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Australia: ATO issues additional guidance on public CbC reporting
The guidance outlines several benefits of voluntary registration. The Australian Taxation Office (ATO) released additional guidance on its public country-by-country (CbC) regime on 12 June 2025. The guidance outlines several benefits of voluntary
See MoreAustralia: BoT consults on revised tax transparency code to align with public CbC reporting
Australia’s Board of Taxation has launched a consultation on 5 June 2025, proposing updates to simplify the Voluntary Tax Transparency Code (VTTC). Australia’s Board of Taxation (BoT), which oversees Australia's Voluntary Tax Transparency
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Denmark: Parliament simplifies transfer pricing rules, lowers documentation requirements
The revised rules, which will apply from the 2025 income year, are expected to exempt at least 1,500 companies that submitted documentation for the 2022 fiscal year. Denmark’s Parliament has passed amendments to Sections 39 and 40 of the
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Taiwan clarifies transfer pricing report rules for Tax Year 2024
Taiwan’s Ministry of Finance has outlined documentation requirements for 2024 controlled transactions, allowing certain enterprises to submit alternative evidence instead of a full transfer pricing report. Taiwan’s Ministry of Finance has
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OECD issues updated guidance on common Country-by-Country reporting errors
The OECD released an updated document on common errors by multinational enterprises (MNEs) in preparing Country-by-Country (CbC) reports on 22 May 2025. The Organisation for Economic Co-operation and Development (OECD) released an updated
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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
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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
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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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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
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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
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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
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