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
See MoreTunisia: 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
See MoreAustralia 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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Taiwan: MoF reminds businesses of Master File and CbC report deadline
The Taiwan's Ministry of Finance (MoF) reminded profit-seeking enterprises that the deadline for submitting Master Files and Country-by-Country (CbC) reports for the fiscal year 2024 is 31 December 2025. This announcement was made on 28 November
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Cyprus: Tax department issues guidance on bilateral CbC reporting agreement with the US
The Cyprus Tax Department, in an announcement on 25 November 2025, clarified that all legal entities and their representatives are covered by the bilateral Competent Authority Agreement for the exchange of Country-by-Country (CbC) reports between
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UK retains SME transfer pricing exemption, plans new multinational reporting regime
The UK government will maintain its current transfer pricing exemption for small and medium-sized enterprises (SMEs), while moving ahead with plans to introduce a new International Controlled Transactions Schedule (ICTS) for multinational
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Australia extends CbC reporting deadline
The Australian Taxation Office (ATO) has announced a lodgment deferral for country-by-country (CbC) reporting entities, extending the deadline for filing CbC statements to 30 January 2026. Under the deferral, in-scope entities must lodge all
See MoreGeorgia implements several tax code modifications for 2026, strengthens transfer pricing rules
Georgia has issued Law No. 1061-IVМС-XIМП dated 12 November 2025 in the Official Gazette, introducing several amendments to the Georgian Tax Code. The amendments introduce targeted incentives for agriculture, capital markets, construction, and
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Sweden: Parliament adopts amendments to interest deduction rules
The Swedish parliament (Riksdag) approved a law that includes targeted amendments to the Income Tax Act on 19 November 2025 regarding interest deduction rules to ensure compliance with EU law. The new law denies deductions for intra-group loans
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