Taiwan: MOF revises penalty rules to ease CRS compliance for financial institutions
Taiwan's Ministry of Finance (MOF) announced, on 24 December 2025, amendments to Article 2-1 and Article 2-2 of the Standards for the Exemption of Penalties for Misconduct in Taxation Affairs, along with updates to the Reference Table for Fines and
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Brazil: RFB updates automatic information exchange rules to include digital currencies, crypto-assets
Brazil’s Federal Revenue Service (RFB) issued Normative Instruction RFB 2298 on 26 December 2025, updating the Common Reporting Standard (CRS) in line with the latest OECD version. Effective 1 January 2026, Key updates include the
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Poland: MoF updates 2024 transfer pricing guide on foreign currency conversion
Poland’s Ministry of Finance (MoF) published updated FAQs in the sixth edition of the TPR Guide – Questions and Answers on 31 October 2025, providing clarification on 2024 transfer pricing reporting obligations. The updates address revised
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Belgium updates transfer pricing documentation rules
Belgium published the Royal Decree of 7 December 2025 in the Official Gazette on 19 December 2025, which repeals the previous Royal Decree of 16 June 2024 concerning transfer pricing documentation. Under the new decree, taxpayers are no longer
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Korea (Rep.) issues 2025 MAP guidelines for international tax disputes
Korea (Rep.)’s National Tax Service (NTS) on 18 December 2025 published online the 2025 Guidelines for Requesting Mutual Agreement Procedure (MAP) Assistance, providing a comprehensive framework for resolving international tax disputes with treaty
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UN: Intergovernmental Negotiating Committee continues discussions on Framework Convention
The Intergovernmental Negotiating Committee (INC) on the UN Framework Convention met in Nairobi for further discussions from 10th to 19th November 2025. Discussions focused on a draft template of a Framework Convention published for consultation in
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Russia updates list of jurisdictions for automatic CbC report exchange
The Federal Tax Service (FTS) of Russia has revised the list of jurisdictions that automatically exchange Country-by-Country (CbC) tax reports. The changes were issued in Order No. ЕД-7-17/884 on 11 December 2025. The updated list now covers 60
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Argentina: ARCA raises transfer pricing reporting thresholds
Argentina’s Federal Tax Administration (ARCA) has increased the revenue thresholds that trigger mandatory transfer pricing documentation, aiming to streamline reporting requirements for multinational and local taxpayers. The changes are set out
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Egypt: MoF increases transfer pricing documentation threshold
Egypt’s Ministry of Finance (MoF) has issued Minister of Finance Decision No. 534 of 2025 of 17 December 2025, revising the rules for transfer pricing (TP) documentation. Under the decision, the annual related-party transaction threshold for TP
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UN: 31st Session of Committee of Experts on Tax Cooperation
The UN Committee of Experts on International Cooperation in Tax Matters held its 31st session from 21 to 24 October 2025. This was the first meeting of the new membership of 25 tax experts appointed for a four-year term from 2025 to 2029. The new
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Belgium: FPS extends CbC filing deadline
Belgium’s Federal Public Service (FPS) Finance has postponed the filing deadline for the Country-by-Country (CbC) notification (275.CBC.NOT) for financial years closing on 31 December 2025. Under the extension, taxpayers now have until 28
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Hungary ratifies GIR MCAA
Hungary published Act XC of 2025 in the Official Gazette on 16 December 2025, ratifying the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA). Hungary joined the GIR MCAA, under Pillar 2 of the OECD/G20
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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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