Costa Rica gazettes new resolution on transfer pricing information return
The new resolution will take effect on 4 August 2025, replacing the 2016 and 2017 resolutions. Costa Rica's Tax Administration (DGT) has published Resolution MH-DGT-RES-0026-2025 in the Official Gazette on 24 July 2025, which pertains to the
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OECD updates signatories list for MCAA-CbC as of July 2025
The last updated list of signatories for MCAA-CbC was released in April 2025. The Organisation for Economic Cooperation and Development (OECD) released an updated list of signatories, along with their signing dates, for the Multilateral
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Luxembourg approves draft laws on Pillar Two, crypto reporting
The approved draft laws transpose DAC 8 and DAC 9, introducing new crypto reporting obligations and implementing Pillar Two top-up tax information exchange, among others. Luxembourg’s Government Council approved a series of draft laws and
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Argentina joins CRS MCAA
As of 25 July 2025, 55 jurisdictions have signed the Addendum to the CRS MCAA. Argentina signed the Addendum to the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (CRS MCAA) on 1 July
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France approves Amount B simplified transfer pricing method for transactions with developing countries
France will restrict the use of the OECD's Amount B transfer pricing method to transactions with developing nations that have adopted the method and have a bilateral tax treaty with France, excluding non-qualifying jurisdictions. France
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European Commission adopts proposal for council decision on amending protocol to AEOI-CRS agreement with Andorra
The European Commission adopted a decision on 17 July 2025 to authorise signing a protocol with Andorra for automatic exchange of financial account information under the OECD's common reporting standard. The European Commission (EC) adopted
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OECD publishes peer review reports on tax information exchange for Honduras, Madagascar, Mongolia, Oman, Trinidad and Tobago
The reports were approved by the Global Forum's dedicated Peer Review and Monitoring Group in June 2025 and subsequently adopted by the Global Forum members. The OECD has published new peer review reports on tax information exchange for Honduras,
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France: DGFIP publishes Charter governing APAs to modernise and strengthen framework
Optional in 2025, the charter strengthens mutual commitments to optimise the APA process. The French tax authorities (DGFIP) published a new Charter governing advance pricing agreements (APAs) to modernise and strengthen the APA framework on 16
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Ukraine clarifies transfer pricing penalty changes effective from March 2025
These amendments, which took effect on 25 March 2025, adjust the penalties applicable to late or missing submissions of TP-related reports and notifications. The Ukrainian State Fiscal Service issued a clarification on upcoming changes to the Tax
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Germany suspends new advance pricing agreements with China
Until further notice, the BZSt, as the competent authority for APAs, will not initiate any new procedures aimed at concluding APAs with China. Germany has temporarily suspended the initiation of new advance pricing agreements (APAs) with China,
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EU publishes implementing regulation to facilitate automatic exchange of tax information under DAC9
The EU's implementing regulation under DAC9 aims to enable automatic information exchange between Member States through technical solutions. The European Commission has published the implementing regulation in the Official Journal of the EU
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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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Poland: MoF issues guidance on beneficial ownership for withholding tax
The guidance provides clarification of the application of the beneficial owner clause for withholding tax under Corporate and Individual Income Tax Laws. Poland’s Ministry of Finance has issued guidance on 3 July 2025, regarding the application
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Indonesia mandates income tax withholding by e-commerce and online platforms
The regulation introduces income tax withholding requirements for both domestic and foreign e-commerce and online marketplace operators. Indonesia's Ministry of Finance announced Regulation No. 37 of 11 June 2025 (PMK37/2025) on 14 July 2025,
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Slovak Republic adopts DAC8 law
The bill will take effect on 1 January 2026. The Slovak Republic has published a bill amending the Act on Automatic Exchange of Information on Financial Accounts for Tax Administration purposes in the Collection of Laws on 10 July 2025. This
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Denmark updates DAC7 guidance for platform reporting obligations
Revised guidance outlines 2024 platform income reporting rules and updates for rental platforms. Denmark’s tax authorities have released revised guidance on implementing the Amending Directive to the 2011 Directive on Administrative Cooperation
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Kenya repeals digital assets tax, expands economic presence tax under Finance Act 2025
The Finance Act 2025 introduces a 10% excise duty on virtual asset transaction fees, expanded SEP tax, a 5-year loss carry forward limit, AMT, and new APA guidelines. Kenya’s President William Ruto signed the Finance Act 2025 into law on 26
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EU, Switzerland to amend agreement on automatic financial information exchange
The agreement enables automatic financial account information exchange between EU Member States and Switzerland under the OECD's Common Reporting Standard (CRS). The European Commission has proposed a Council Decision on 10 July 2025 to amend the
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