Finland updates BEPS MLI stance on Brazil tax treaty, including corrections
Finland submitted an updated consolidated position for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI), as noted by the OECD on 11 December 2025. This update includes two specific corrections regarding
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Australia: ATO consults transfer pricing considerations for inbound distribution models
The Australian Taxation Office (ATO) has initiated a consultation on a draft update to Practical Compliance Guideline PCG 2019/1, concerning transfer pricing considerations for inbound distribution arrangements. This includes updated profit
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Qatar: GTA launches ‘Tabadol’ portal for CbC reports
Qatar’s General Tax Authority (GTA) announced the launch of the “Tabadol” portal for submitting Country-by-Country Reports (CbCR) for the 2024 fiscal year, along with notifications for 2025, on 10 December 2025. The submission deadline is
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France strengthens transfer pricing rules under 2024 Finance Act
France has introduced new measures to reinforce the administration’s ability to detect and penalise abusive transfer pricing practices, following the publication of updates linked to Article 116 of Finance Act No. 2023-1322 of 29 December 2023 for
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Poland: Council of Ministers approves draft Crypto-Assets Market Act
Poland’s Council of Ministers has adopted the draft act on the crypto-assets market on 8 December 2025, which is identical to the draft legislation passed by the Sejm (lower house of the parliament) on 7 November 2025. The Act ensures the
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Cyprus: Tax Department clarifies bilateral agreement with US for exchange of CbC reports
The Cyprus Tax Department has issued a notice, on 25 November 2025, regarding the anticipated effective date of the agreement for the exchange of Country-by-Country (CbC) reports with the US and the related local filing requirements. The Tax
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Argentina: ARCA consults draft transfer pricing regulation
Argentina’s tax and customs agency (ARCA) has initiated a public consultation on a draft regulation to replace General Resolution No. 4717/2020 on transfer pricing and international transactions on 9 December 2025. This resolution, which
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Tunisia mandates electronic submission of tax returns, transfer pricing declaration
Tunisia’s tax administration, the Directorate General of Taxes, issued a notice on 11 November 2025, informing taxpayers, who are required to file tax returns, and legal entities, who are required to submit the annual transfer pricing declaration,
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Algeria gazettes mutual assistance convention
Algeria published in the Official Gazette the decree ratifying the OECD–Council of Europe Convention on Multilateral Convention on Mutual Administrative Assistance in Tax Matters (the Convention) as amended by the 2010 protocol on 30 November
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Tunisia: Ministry of Finance announces deadline for 2024 CbC reporting
Tunisia’s tax administration has issued a notice reminding taxpayers of their obligation to submit Country-by-Country (CbC) reports for the 2024 fiscal year by 31 December 2025, in accordance with the conditions set out in the Code of Tax Rights
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Australia: ATO publishes final guidance on public CBC reporting exemptions
The Australian Taxation Office published Practice Statement Law Administration PS LA 2025/2, Public country-by-country reporting exemptions, on 8 December 2025. The statement sets out the administrative approach to the Commissioner's discretion for
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Australia enacts stricter beneficial ownership rules, extends tax incentives for small businesses
The Treasury Laws Amendment (Strengthening Financial Systems and Other Measures) Bill 2025 cleared both chambers of the Australian Parliament on 27 November 2025, without any changes to the version initially introduced. The final steps before it
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Honduras: Deadline approaches for MNE group CbC reporting notification
Multinational enterprise (MNE) groups operating in Honduras must submit their Country-by-Country (CbC) reporting notification by 31 December 2025, in line with Agreement SAR-653-2023, published in the Official Gazette on 19 March 2024. Under the
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Ireland: Irish Revenue updates guidance on anti-hybrid rules for partnerships
The Irish Revenue has issued eBrief No. 223/25, on 27 November 2025, on the country’s anti-hybrid rules, reflecting changes to the application of the associated enterprises test for partnerships. Tax and Duty Manual Part 35C-00-01 has been
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OECD: Global Forum reports historic progress in tax transparency, crypto disclosure
The 18th plenary of the Global Forum on Transparency and Exchange of Information for Tax Purposes took place in New Delhi on 2 December 2025, alongside the release of its 2025 Annual Report. The report highlights significant advances in global
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Hungary consults overhaul of transfer pricing documentation rules
Hungary’s Ministry of National Economy announced, on 2 December 2025, that it is inviting feedback on a proposed overhaul of its transfer pricing documentation rules. The revision aims to clarify reporting requirements, expand the information
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Georgia expands BEPS MLI coverage through 22 additional treaties
According to an OECD update, Georgia submitted an updated consolidated position for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) on 27 November 2025. The update notably expands the list of Georgia’s
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UK: HMRC outlines reforms to transfer pricing, PE rules, DPT for 2026
The UK’s HM Revenue & Customs (HMRC) on 26 November published a policy paper outlining extensive reforms to the UK’s transfer pricing framework, permanent establishment (PE) rules and the Diverted Profits Tax (DPT). The update follows a
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