Poland gazettes consolidated transfer pricing rules for corporate tax
Poland published the updated consolidated text of the transfer pricing regulations related to corporate income tax in the Official Gazette on 8 April 2025, reflecting the provisions which have been in effect from 21 March 2025. The provisions of the
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Germany releases 2025 CRS reporting list with new jurisdictions
The German Federal Central Tax Office has published a provisional list of jurisdictions for the Common Reporting Standard (CRS) financial account information exchange for 2025 on 26 March 2025. . This list covers jurisdictions that will
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India: CBDT signs record number of advance pricing agreements in FY 2024-25
The Indian Central Board of Direct Taxes (CBDT) announced that India has entered into a record 174 Advance Pricing Agreements (APAs) with Indian taxpayers in FY 2024-25. These include Unilateral APAs (UAPAs), Bilateral APAs (BAPAs) and Multilateral
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Switzerland revises jurisdictions for CbC report exchange
Switzerland has updated its list of jurisdictions for exchanging Country-by-Country (CbC) reports. The latest version was published on 28 March 2025. The latest update adds three new jurisdictions to the list. The Dominican Republic and Vietnam
See MoreGermany: Ministry of Finance clarifies application of CbC reporting for transparent partnerships
Germany’s Federal Ministry of Finance published a letter on 3 April 2025 addressing how Country-by-Country (CbC) reporting applies to tax-transparent partnerships, including their treatment under the Transitional CbCR Safe Harbour for Pillar
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New Zealand: Parliament grants Royal Assent for Omnibus Tax Bill
New Zealand’s Parliament announced on 29 March 2025 that royal assent had been granted to Public Act No. 9/2025, a comprehensive omnibus tax law. The Bill introduces several key provisions, including confirming annual income tax rates for the
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Cayman Islands updates CRS jurisdiction lists
The Cayman Islands updated its lists of participating and reportable jurisdictions in the Official Gazette on 31 March 2025 for automatic financial account information exchange under the Common Reporting Standard (CRS). The list of participating
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Germany mandates transaction matrix transfer pricing documentation requirement
Germany’s Ministry of Finance released a decree outlining the requirements for the “transaction matrix,” a new component of transfer pricing documentation under section 90(3) of the Fiscal Code (AO) on 2 April 2024. The transaction matrix
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OECD adds Guernsey to list of qualified Pillar Two jurisdictions
The OECD issued an update on 31 March 2025, in which Guernsey has been added as a jurisdiction with a qualified income inclusion rule (IIR), domestic minimum top-up tax rule (QDMTT), and meeting QDMTT safe harbor standards. This should prevent
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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
See MoreSwitzerland 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
See MoreUkraine 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
See MoreGermany 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
See MoreIndia: 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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