Slovak Republic updates transfer pricing documentation guidelines
Regfollower Desk The Slovak Republic’s Ministry of Finance has released updated guidelines on transfer pricing documentation (MF/012879/2025-724) and introduced a new 2025 corporate income tax return form, which includes a redesigned “Table I
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Australia: Federal Court pauses Oracle royalty tax case to permit treaty arbitration with Ireland
The Full Federal Court of Australia ruled in favour of Oracle, allowing its Mutual Agreement Procedure with Ireland to proceed by staying domestic tax proceedings, reaffirming taxpayers’ treaty rights to prevent double taxation over intra-group
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Hungary: National Assembly automatic exchange of information on crypto-assets, financial accounts, digital platform income
Hungary’s National Assembly ratified three OECD agreements—CARF MCAA, CRS MCAA Addendum, and DPI-MCAA—to enhance automatic exchange of information on crypto-assets, financial accounts, and digital platform income Regfollower
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Slovenia: FURS announces CbC filing deadline for 2024 reports
Reporting entities must submit CbC reports in accordance with the delivery instructions published in Annex 21 of the Rules Amending the Rules on the Implementation of ZDavP-2 (Official Gazette of the Republic of Slovenia, Nos. 30/17, 37/18 and
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European Commission unveils 2026 work programme, signalling withdrawal of key tax proposals
EU unveiled 2026 plan on 21 October 2025 to boost sovereignty, security, and competitiveness. The European Commission has presented its 2026 work programme, outlining a series of initiatives aimed at strengthening Europe’s sovereignty,
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UN Tax Committee progresses on extractives, digital tax, transfer pricing initiatives
The UN Tax Committee reviewed proposals to establish new workstreams on extractive industries, digital economy, and transfer pricing—aiming to enhance guidance on critical minerals valuation, digital services and remote work taxation, and transfer
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Kazakhstan 2026 tax code: A full reset of the country’s approach to corporate taxation
Kazakhstan’s new Tax Code, coming into force on 1 January 2026, is more than a technical rewrite. It’s a full reset of the country’s approach to corporate taxation, profit allocation, and cross-border oversight. Behind the headlines of
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OECD publishes the third batch of updated transfer pricing country profiles
The OECD has published updated transfer pricing country profiles for 25 jurisdictions, adding new profiles for Cabo Verde, Guatemala, Thailand, the UAE, and Zambia. The OECD has released a new batch of updated transfer pricing country profiles on
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Netherlands: MoF consults on tax measures for cross-border transactions
The consultation ends on 1 December 2025. The Netherlands Ministry of Finance initiated a public consultation on 20 October 2025 on a draft legislation outlining tax-related accompanying measures for cross-border transactions. The proposed
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Australia: ATO releases updated guidance on transitional CbC safe harbour rules for global and domestic minimum tax
The updated guidance will help taxpayers determine whether the transitional CBC reporting safe harbour applies and how it may simplify their Pillar Two compliance obligations. The Australian Taxation Office (ATO) has released updated Global and
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France: Parliament releases 2026 draft finance bill, features extended exceptional taxes on corporations
For 2026, France plans to extend the temporary corporate income surtax at reduced rates for large companies, accelerate the phased elimination of the CVAE business tax, and update global minimum tax rules. France’s parliament has released the
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Denmark expands CbC reporting requirements
Denmark expanded CbC reporting, requiring full entity details from 1 January 2028. The Danish government has published Executive Order No. 1157 on 9 September 2025, broadening the scope of information that multinational enterprise (MNE) groups
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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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Ecuador, Romania sign CRS MCAA addendum
The two countries signed the addendum on 3 September 2025, updating CRS rules to cover crypto-assets and strengthen reporting and due diligence. The OECD has announced that Ecuador and Romania signed the Addendum to the Multilateral Competent
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Germany: MOF consults filing rules for GloBE Information Return
Stakeholders are requested to submit feedback on the draft by 6 October 2025. The German Ministry of Finance (MOF) published a draft ordinance setting out the rules for filing and exchanging the GloBE Information Return (GIR) on 29 September
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Brazil, US sign agreement on automatic tax data sharing
The arrangement creates a formal system for Brazil and the U.S. to automatically share tax information under their 2007 agreement. The U.S. Internal Revenue Service (IRS) and Brazil have published a competent authority arrangement on 27 August
See MoreOECD: Finland, Liechtenstein, and Norway join GIR MCAA
In total, 20 countries have signed the agreement as of 30 September 2025. According to an OECD update on 30 September 2025, Finland, Liechtenstein, and Norway have signed the Multilateral Competent Authority Agreement on the Exchange of GloBE
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