Argentina ratifies BEPS multilateral instrument (MLI)
Argentina's President ratified the Multilateral Convention to Prevent BEPS (MLI) on 28 May 2025. Argentina’s President has signed Decree No. 361/2025, ratifying Law No. 27.788 and the Multilateral Convention to Implement Tax Treaty Measures to
See More
Germany deposits notifications for MLI entry into force with Czech Republic and Japan
Germany has confirmed completion of its internal procedures for the MLI, enabling its application to tax treaties with the Czech Republic and Japan from 1 January 2026. Germany has deposited its notifications confirming the completion of internal
See More
Taiwan clarifies transfer pricing report rules for Tax Year 2024
Taiwan’s Ministry of Finance has outlined documentation requirements for 2024 controlled transactions, allowing certain enterprises to submit alternative evidence instead of a full transfer pricing report. Taiwan’s Ministry of Finance has
See More
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
See More
Algeria extends 2024 transfer pricing filing deadline
The deadline has been further extended to 5 June 2025. Algeria's Directorate General of Taxes announced on 28 May 2025 an extension of the 2024 transfer pricing declaration deadline for the 2024 financial year. Algeria’s tax authorities have
See More
Denmark adopts DAC8 crypto-asset reporting rules
Denmark enacted Act No. 409 of 29 April 2025, aligning with EU Directive 2023/2226 (DAC8) to introduce new reporting and due diligence requirements for crypto-asset service providers. Denmark has published Act No. 409 of 29 April 2025 in the
See More
Mexico reports higher tax revenue from transfer pricing audits during FY 2019-24
SAT announced results from its audit strategies, highlighting increased tax collection from large taxpayers for the periods 2013-2018 and 2019-2024. Mexico’s Tax Administration Service (SAT), in a press release dated 26 May 2025, highlighted
See More
Denmark: Supreme Court rules arm’s length pricing need not align with interquartile range
The case examined EET Group's taxable income from 2010 to 2012, focusing on revenue from goods sold to seven sales subsidiaries. Denmark’s Supreme Court issued a ruling on the arm's length pricing of transactions between the Danish EET Group
See More
Sweden proposes DAC8 implementation bill for 2026
Sweden has proposed a bill to implement the EU's DAC8 directive on tax cooperation, introducing new rules for the automatic exchange of information on crypto-assets and securities. The regulations will take effect on 1 January 2026. The Swedish
See More
OECD issues updated guidance on common Country-by-Country reporting errors
The OECD released an updated document on common errors by multinational enterprises (MNEs) in preparing Country-by-Country (CbC) reports on 22 May 2025. The Organisation for Economic Co-operation and Development (OECD) released an updated
See More
Australia: Administrative Review Tribunal rules in favour of Alcoa against ATO in key transfer pricing ruling
This case focused on a major transfer pricing issue, where ATO claimed Alcoa underpriced its alumina sales to Aluminium Bahrain B.S.C. (Alba) from 1993 to 2009, causing a tax shortfall of over AUD 213 million. Australia’s Administrative Review
See More
UK proposes tighter transfer pricing rules, replacing diverted profits tax with new UTPP
The UK government will tighten transfer pricing rules and replace the diverted profits tax with a new corporation tax charge. The government has announced plans to revise the UK's international tax framework, which involves narrowing the
See More
EU: Council adopts VAT and tax recovery stance in UK trade deal
The Decision replaces Annex I to Decision 4/2023, which outlines standard forms for sharing information and data, exchanging information by using the Common Communication Network, and arranging contact between central liaison offices and liaison
See More
OECD publishes new transfer pricing profiles for Azerbaijan and Pakistan, updates 11 others
The OECD has published updated transfer pricing country profiles for 11 jurisdictions. RegFollower Desk The Organisation for Economic Co-operation and Development (OECD) has released new transfer pricing country profiles for Azerbaijan and
See More
Poland: Council of Ministers approve bill to ease group taxation, transfer pricing rules
Poland's Council of Ministers approved a proposal to simplify group taxation and transfer pricing regulations on 21 May 2025. Poland’s Council of Ministers approved a proposal on 21 May 2025 to streamline the country’s group taxation and
See More
Finland updates CRS participating jurisdictions list
The Finnish Tax Administration has published an updated list of participating jurisdictions for exchanging financial account information under the Common Reporting Standard (CRS) on 15 May 2025. The Common Reporting Standard (CRS), developed in
See More
Italy updates reportable and participating jurisdictions under CRS
Italy’s Ministry of Economy and Finance has issued a decree updating the list of jurisdictions considered reportable and participating under the Common Reporting Standard (CRS). The updated list, released in the Official Journal on 6 May 2025,
See More
Argentina: Senate ratifies BEPS MLI
Argentina's Senate approved the law to ratify the Multilateral Convention on Tax Treaty Measures to Prevent Base Erosion and Profit Shifting (MLI) on 7 May 2025. The Chamber of Deputies approved it in October 2024. Once the internal
See More