Korea (Rep.): Ministry of Economy and Finance proposes corporate tax hikes, AI investment incentives, QDMTT Pillar Two rules
The proposals will require approval from the National Assembly before they can enter into force. The South Korean Ministry of Economy and Finance released the 2025 tax law amendment proposal, on 31 July 2025, which includes corporate tax hikes,
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Romania gazettes legislation to amend APA, MAP
The legislation updates rules for Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) Romania’s government published Emergency Ordinance 11/2025 (GEO 11/2025) in the Official Gazette No. 695 on 24 July 2025, to amend the
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Kazakhstan adopts transfer pricing law amendments, emphasises ‘substance over form
Kazakhstan’s President signed amendments to transfer pricing regulations on 18 July 2025, introducing new rules effective 1 January 2026 that emphasize substance over form, revise reporting thresholds, define key financial terms, and tighten
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Bolivia: National Tax Service extends filing deadlines for corporate tax, transactions declarations
Corporate tax returns for tax years ending 31 March 2025 are now due by 29 August 2025. Bolivia’s National Tax Service (SIN) issued Resolution No. 102500000032 on 28 July 2025, in which it extended filing deadlines for corporate income tax
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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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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 2025Â
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 MCAAÂ
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,
See MoreFrance: 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,
See MoreEU 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
See MoreKazakhstan 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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