Norway will not implement Amount B but will accept it from other jurisdictions
The Norwegian Tax Administration published a release on 31 March 2025 outlining the implementation of Amount B, which aims to simplify transfer pricing rules under Pillar One. Norway’s Ministry of Finance has decided that amount B shall not be
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UK consults advance tax clearance service for large innovative investment projects, transfer pricing treatment of CCAs
The Chancellor of the Exchequer announced that the government launched a consultation on a proposed new service aimed at providing advance statutory certainty on the application of UK corporation tax rules for businesses undertaking the "very
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India enacts Finance Act 2025, offers support for targeted sectors of the economy
India's Central Board of Direct Taxes (CBDT) has released the Finance Act 2025 on 29 March 2025. The Act was officially enacted on 29 March 2025, following the President's assent, implementing the provisions outlined in the 2025–2026
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Ukraine: State Tax Service highlights possibility of concluding АРА agreement
Ukraine’s State Tax Service, in a release, highlighted the possibility of concluding Advance Pricing Arrangement (АРА) on 28 March 2025. Transfer pricing rules in Ukraine, introduced since 2013, are a tool to combat tax evasion and ensure
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US: IRS report shows decline in APA executions and completion times in 2024
The US Internal Revenue Service (IRS) released Announcement 2025-13 - Announcement and Report Concerning Advance Pricing Agreements on 27 March 2025. The report outlines the experience, structure, and activities of the Advance Pricing and Mutual
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Switzerland updates MCAA-CbC participation list, adds Dominican Republic, Trinidad and Tobago, Vietnam
The Swiss Official Gazette published Decision No. RO 2025 214 on 28 March 2025 which updates the list of countries participating in the Multilateral Competent Authority Agreement (MCAA) for the exchange of country-by-country reports (CbCR). The
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Ukraine issues guidance on CbC reporting for US parent multinationals
The State Tax Service of Ukraine issued a guidance letter (No. 1308/IPK/99-00-21-02-03 IPK) on 12 March 2025 regarding the requirement for Ukrainian entities to submit a Country-by-Country (CbC) report on behalf of their US-based parent
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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
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India: CBDT expands transfer pricing safe harbour rules and raises transaction limits for select services
India’s Central Board of Direct Taxes (CBDT) issued Notification No. 21/2025 on 25 March 2025, introducing the Income-tax (Sixth Amendment) Rules, 2025. This encompasses three key modifications to the safe harbour rules for international
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Finland 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
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UN Tax Committee: Guidance on Indirect Taxes
At the meeting of the UN Tax Committee on 27 March 2025 the subcommittee dealing with indirect taxation matters put forward some potential issues that the next membership of the Tax Committee may wish to consider at future sessions. The
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On 25 March 2025 the Subcommittee on the Extractive Industries taxation presented to the UN Tax Committee a draft supplement to Chapter 5 (tax incentives) of the UN Handbook on Selected Issues for Taxation of the Extractive Industries; draft
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Russia mandates transfer pricing method in controlled transaction notifications
Russia's Federal Tax Service (FTS) issued Letter No. ШЮ-4-13/2827@ on 13 March 2025 about the notification of controlled transactions. It clarifies that from 2024, taxpayers must disclose the transfer pricing method used to justify the market
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UN Tax Committee: Transfer Pricing Subcommittee Discusses Future Guidance
On 26 March 2025 the UN Tax Committee discussed their transfer pricing work. Since the previous session of the Committee, the Subcommittee on Transfer Pricing has gathered feedback from members on possible future workstreams that could be pursued by
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UN: New Article 12AA on Taxation of Services Presented for Approval
The 30th session of the UN Committee of Experts on International Cooperation in Tax Matters is being held from 24 to 27 March 2025. On 25 March 2025 the Subcommittee on Taxation Issues Related to the Digitalized and Globalized Economy presented
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Moldova updates transfer pricing rules, adds new APA regulations
Moldova published Order No. 21 of 11 March 2025 in the Official Gazette on 14 March 2025, establishing rules for the country's new transfer pricing regime. The Order No. 21 of 11 March 2025 amends Order No. 9 of 26 January 2024. A key change
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Mauritius updates CRS reportable and participating jurisdictions
The Mauritius Revenue Authority has updated its lists of reportable and participating jurisdictions for the automatic exchange of financial account information under the Common Reporting Standard (CRS). The reportable jurisdictions list includes
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