Kazakhstan 2026 tax code: A full reset of the country’s approach to corporate taxation
Kazakhstan’s new Tax Code, coming into force on 1 January 2026, is more than a technical rewrite. It’s a full reset of the country’s approach to corporate taxation, profit allocation, and cross-border oversight. Behind the headlines of
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OECD publishes the third batch of updated transfer pricing country profiles
The OECD has published updated transfer pricing country profiles for 25 jurisdictions, adding new profiles for Cabo Verde, Guatemala, Thailand, the UAE, and Zambia. The OECD has released a new batch of updated transfer pricing country profiles on
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Netherlands: MoF consults on tax measures for cross-border transactions
The consultation ends on 1 December 2025. The Netherlands Ministry of Finance initiated a public consultation on 20 October 2025 on a draft legislation outlining tax-related accompanying measures for cross-border transactions. The proposed
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Australia: ATO releases updated guidance on transitional CbC safe harbour rules for global and domestic minimum tax
The updated guidance will help taxpayers determine whether the transitional CBC reporting safe harbour applies and how it may simplify their Pillar Two compliance obligations. The Australian Taxation Office (ATO) has released updated Global and
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France: Parliament releases 2026 draft finance bill, features extended exceptional taxes on corporations
For 2026, France plans to extend the temporary corporate income surtax at reduced rates for large companies, accelerate the phased elimination of the CVAE business tax, and update global minimum tax rules. France’s parliament has released the
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Denmark expands CbC reporting requirements
Denmark expanded CbC reporting, requiring full entity details from 1 January 2028. The Danish government has published Executive Order No. 1157 on 9 September 2025, broadening the scope of information that multinational enterprise (MNE) groups
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Sweden: MoF proposes amending targeted interest deduction limitation rules
The changes are aimed at adjusting the interest deduction rules to align with EU regulations. The Swedish Ministry of Finance (MOF) has released a draft bill 2025/26:20 outlining specific changes to the Income Tax Act, aimed at adjusting
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Bulgaria consults proposed transfer pricing reforms, positions to match OECD standards
The consultation is set to conclude on 23 October 2025. Bulgaria has initiated a public consultation on its proposed draft regulations to update its transfer pricing regulations as part of its efforts to join the Organisation for Economic
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Ecuador, Romania sign CRS MCAA addendum
The two countries signed the addendum on 3 September 2025, updating CRS rules to cover crypto-assets and strengthen reporting and due diligence. The OECD has announced that Ecuador and Romania signed the Addendum to the Multilateral Competent
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Germany: MOF consults filing rules for GloBE Information Return
Stakeholders are requested to submit feedback on the draft by 6 October 2025. The German Ministry of Finance (MOF) published a draft ordinance setting out the rules for filing and exchanging the GloBE Information Return (GIR) on 29 September
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Brazil, US sign agreement on automatic tax data sharing
The arrangement creates a formal system for Brazil and the U.S. to automatically share tax information under their 2007 agreement. The U.S. Internal Revenue Service (IRS) and Brazil have published a competent authority arrangement on 27 August
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OECD: Finland, Liechtenstein, and Norway join GIR MCAA
In total, 20 countries have signed the agreement as of 30 September 2025. According to an OECD update on 30 September 2025, Finland, Liechtenstein, and Norway have signed the Multilateral Competent Authority Agreement on the Exchange of GloBE
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Romania joins crypto-asset reporting framework (CARF-MCAA)
Romania plans to begin exchanging information under CARF by 2027. Romania signed the Multilateral Competent Authority Agreement (MCAA) under the Crypto-Asset Reporting Framework (CARF) on 3 September 2025. This framework standardizes the
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US: Court of Appeals determines tax authorities cannot reallocate income beyond a taxpayer’s legal entitlement
The IRS sought to reallocate an additional USD 23.7 million in royalties to 3M under the arm’s-length standard, despite the company’s Brazilian subsidiary being legally limited to paying only USD 5.1 million. The US Court of Appeals for the
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OECD: Australia, Belgium, Netherlands, New Zealand revise arbitration rules under BEPS MLI
Part VI of the MLI enables jurisdictions that opt in to implement mandatory binding arbitration to resolve disputes arising under tax treaties. The OECD has released updated arbitration profiles for Australia, Belgium, Netherlands, and New
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Peru: BEPS MLI enters into force
Peru’s BEPS MLI entered into force on 1 October 2025 to curb tax treaty abuse and base erosion by multinationals. The Multilateral Convention on Tax Treaty Measures to Counter Base Erosion and Profit Shifting (MLI) has entered into force in
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Mexico updates list of registered non-resident digital service providers
Under the rules, which have applied since 1 June 2020, non-resident digital service providers must register with the Federal Registry of Taxpayers (RFC) to supply services to Mexican users. The Mexican Tax Administration (SAT) issued Official
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Argentina deposits BEPS MLI ratification instrument
The MLI is set to take effect in Argentina starting 1 January 2026. Argentina officially ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) by depositing its instrument
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