Singapore: IRAS revises e-tax guide on hybrid instrument taxation
The Inland Revenue Authority of Singapore (IRAS) has released the third edition of its e-Tax Guide on the Income Tax Treatment of Hybrid Instruments on 26 December 2025. The guide outlines how hybrid instruments are classified as debt or equity
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Poland: MoF updates 2024 transfer pricing guide on foreign currency conversion
Poland’s Ministry of Finance (MoF) published updated FAQs in the sixth edition of the TPR Guide – Questions and Answers on 31 October 2025, providing clarification on 2024 transfer pricing reporting obligations. The updates address revised
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Ireland: Irish Revenue updates guidance on anti-hybrid rules for partnerships
The Irish Revenue has issued eBrief No. 223/25, on 27 November 2025, on the country’s anti-hybrid rules, reflecting changes to the application of the associated enterprises test for partnerships. Tax and Duty Manual Part 35C-00-01 has been
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Sweden: Parliament adopts amendments to interest deduction rules
The Swedish parliament (Riksdag) approved a law that includes targeted amendments to the Income Tax Act on 19 November 2025 regarding interest deduction rules to ensure compliance with EU law. The new law denies deductions for intra-group loans
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Sweden: MoF proposes amending targeted interest deduction limitation rules
The changes are aimed at adjusting the interest deduction rules to align with EU regulations. The Swedish Ministry of Finance (MOF) has released a draft bill 2025/26:20 outlining specific changes to the Income Tax Act, aimed at adjusting
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Bulgaria consults proposed transfer pricing reforms, positions to match OECD standards
The consultation is set to conclude on 23 October 2025. Bulgaria has initiated a public consultation on its proposed draft regulations to update its transfer pricing regulations as part of its efforts to join the Organisation for Economic
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South Africa: National Treasury withdraws amendment on hybrid equity instruments
National Treasury has retracted its proposal to amend the definition of “hybrid equity instrument” in section 8E of the Income Tax Act following industry concerns. South Africa's National Treasury confirmed that the proposal in the 2025 draft
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South Africa: Treasury proposes strengthening anti-avoidance rules for hybrid equity instruments
South Africa proposes more rigid tax rules on hybrid equity instruments, expanding the scope and taxing dividends as income from 1 January 2026. The South African National Treasury has proposed changes to section 8E of the Income Tax Act to
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Italy implements emergency tax revisions on CFC, hybrid mismatch penalty rules
Urgent tax measures include revising the domestic CFC rules, tax loss carry-forward provisions, and the penalty protection regime for hybrid mismatch assessments. Italy’s parliament converted Law Decree No. 84 of 17 June 2025 into law with
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Netherlands clarifies application of ATAD interest deduction limitations
The Netherlands has issued a new decree clarifying the application of ATAD interest deduction limitations, effective from 30 July 2025. The Netherlands State Secretary for Finance has published Decree no. 2025-17107 of 16 July 2025, in Official
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US: Illinois to tax 50% of GILTI, tightens interest deductions under 2026 budget
Starting with tax years ending on or after 31 December 2025, taxpayers must include 50% of GILTI, as defined under IRC section 951A, in their base income for Illinois tax purposes. Illinois Governor J.B. Pritzker signed a bill (HB 2755) on 16
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Italy extends deadline for penalty protection on hybrid mismatch documentation
Calendar-year taxpayers now have until 31 October 2025 to finalise documentation for the years 2020 through 2024. Italy’s Ministry of Economy and Finance has issued Decree Law No. 84 on 17 June 2025, extending the deadline for taxpayers to
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France sets interest rate caps for shareholder loan deductions in Q2 2025
The French tax authority has updated the interest rates used to determine the deductibility of interest payments to shareholders for companies with fiscal years ending between 31 March 2025 and 29 June 2025. Interest payments that exceed these
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Finland consults on interest deduction limit rule changes for key infrastructure project lenders
Finland’s Ministry of Finance has initiated a public consultation on 9 April 2025, on a draft proposal to Parliament to amend the regulation on the interest deduction limit. The proposal seeks to amend the interest deduction limitation
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UK: HMRC consults transfer pricing framework, permanent establishment rules, diverted profits tax
The UK’s tax authority, His Majesty’s Revenue and Customs (HMRC) has launched consultations seeking public input on potential updates to the UK’s transfer pricing framework, permanent establishment rules and the diverted profits tax on 28
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Norway consulting debt and interest deduction limits for financial firms abroad
Norway’s Ministry of Finance has initiated a public consultation on proposed changes to the Norwegian Tax Act. These amendments limit the deductibility of debt and interest expenses for financial institutions operating abroad. The proposed
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Germany introduces revised rules for interest deduction limitations
The German Ministry of Finance has released updated guidelines on the interest deduction limits, known as the "interest barrier." on 24 March 2025. These changes follow amendments made by the Secondary Credit Market Promotion Act to Sections 4h
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Finland seeks public input on interest deductions
Finland's Ministry of Finance has initiated public consultation on two proposed tax reforms on 27 March 2025. Interest exemption for infrastructure projects The Business Tax Act limits the ability to deduct interest for tax purposes, which
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