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 2025Â 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
See MoreFinland 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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Australia: New law amends luxury car tax, denies interest deductions on tax debtsÂ
Australia’s parliament passed the Treasury Laws Amendment (Tax Incentives and Integrity) Act 2024 on 26 March 2025, which received Royal Assent on 27 March 2025. This follows after Australia’s Senate Economics Legislation Committee has
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UN Tax Committee: Guidance on Indirect Taxes
At the meeting of the UN Tax Committee on 27 March 2025 the subcommittee dealing with indirect taxation matters put forward some potential issues that the next membership of the Tax Committee may wish to consider at future sessions. The
See MoreUN Tax Committee: Extractive Industries Taxation
On 25 March 2025 the Subcommittee on the Extractive Industries taxation presented to the UN Tax Committee a draft supplement to Chapter 5 (tax incentives) of the UN Handbook on Selected Issues for Taxation of the Extractive Industries; draft
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UN Tax Committee: Transfer Pricing Subcommittee Discusses Future Guidance
On 26 March 2025 the UN Tax Committee discussed their transfer pricing work. Since the previous session of the Committee, the Subcommittee on Transfer Pricing has gathered feedback from members on possible future workstreams that could be pursued by
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UN: New Article 12AA on Taxation of Services Presented for Approval
The 30th session of the UN Committee of Experts on International Cooperation in Tax Matters is being held from 24 to 27 March 2025. On 25 March 2025 the Subcommittee on Taxation Issues Related to the Digitalized and Globalized Economy presented
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Peru: Congress approves bill for MLI ratification
The Peruvian Congress approved the bill for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 13 March 2025. Following the internal ratification process,
See MoreOECD: Report on Simplified Peer Review of Iceland under BEPS Action 14
On 4 March 2025 the OECD issued a stage one simplified peer review report on Iceland under BEPS action 14. The report sets out the results of Stage 1 of the simplified peer review of the implementation of the minimum standard on making dispute
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