South Africa proposes SEZ transfer pricing reforms, corporate tax changes in Medium-Term Budget Policy
South Africa’s National Treasury has delivered the Medium-Term Budget Policy Statement (MTBPS) to Parliament on 21 October 2026. This package comprises three key amendment bills designed to implement the government's tax policy, monetary
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Finland proposes interest deduction relief for critical infrastructure projects
Finland’s Parliament is reviewing Government Proposal HE 227/2026 vp, part of the Government’s 2027 Budget package, which proposes a new exception to the country’s interest deduction restriction rules. This legislative change allows
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Netherlands updates interest deduction limitation rules
The Netherlands published Policy Decision No. 2026-17016 of 10 September 2026 from the State Secretary of Finance on 22 September 2026, updating and replacing the 2025 decision on the interest deduction limitation, or earnings stripping,
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Iceland: MoF consults tax law changes on interest deductions, charities, rulings and nicotine products
Iceland’s Ministry of Finance and Economic Affairs (MoF) has initiated a public consultation on several proposed legislative amendments in its draft document on 4 September 2026, with a targeted entry into force on 1 January 2027. These planned
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Taiwan: MOF clarifies reasonable interest on inter-company lending arrangements
Taiwan's Ministry of Finance (MoF) has released a notice on 1 June 2026, reminding taxpayers of the requirements governing reasonable interest on inter-company lending arrangements. To protect the rights and interests of company shareholders and
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Montenegro proposes draft corporate tax rules in accordance to EU ATAD
The Government of Montenegro has released a draft law on Amendments to the Law on Corporate Income Tax, proposing measures to address profit shifting in accordance with the EU Anti-Tax Avoidance Directive (ATAD) (Directive 2016/1164 as amended by
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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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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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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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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 debts
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
See MoreAustralia: Senate report on bill to amend luxury car tax and deny interest deductions on tax debts
Australia’s Senate Economics Legislation Committee has published its report on the Treasury Laws Amendment (Tax Incentives and Integrity) Bill 2024. This follows after the Senate referred the provisions of the Treasury Laws Amendment (Tax
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Poland sets base and margin rates for transfer pricing
Poland has published Notice No. 1105 in the Official Gazette on 21 December 2024, setting the base interest rates and margin interest rates for transfer pricing in individual and corporate income taxes. The regulation establishes base interest
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