Kenya: KRA consults on draft income tax regulations for advance pricing agreement, minimum top-up tax for 2025
The Kenya Revenue Authority (KRA) released two draft regulations for public consultation, covering its global minimum tax regime and advance pricing agreement procedures for 2025, on 3 November 2025. In compliance with the Statutory Instruments
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Australia: ATO publishes draft guidance for public CbC reporting
The Australian Taxation Office (ATO) has published a draft guidance on how to complete the public Country-by-Country (CbC) report on 31 October 2025. The public CbC reporting rules apply for reporting periods starting on or after 1 July 2024, and
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Brazil mandates disclosure of ultimate beneficial owners of investment funds, companiesÂ
Brazil’s Federal Revenue Service published an update to the rule on 31 October 2025, which deals with the identification of the ultimate beneficiaries of investment funds, companies, and legal arrangements operating in the country. This measure
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OECD reports increase in MAP and APA caseloads in 2024 data published on Tax Certainty Day 2025
The OECD has released new tax dispute statistics, highlighting generally positive results despite ongoing challenges on 31 October 2025. Tax certainty: OECD releases new statistics on tax disputes, showing positive outcomes but with challenges
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Argentina tightens reporting rules on cross-border transaction
RF Report Argentina published Decree 767/2025 in the Official Gazette on 28 October 2025, introducing significant updates to its cross-border transaction reporting rules, effective for fiscal years ending on or after 29 October 2025. The
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Australia: ATO updates APA guidance
The Australian Taxation Office (ATO) updated Law Administration Practice Statement PS LA 2015/4 to reflect enhancements to its advance pricing arrangement (APA) programme. The changes incorporate recommendations from the ATO’s 2023 APA Programme
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Slovak Republic updates transfer pricing documentation guidelines
Regfollower Desk The Slovak Republic’s Ministry of Finance has released updated guidelines on transfer pricing documentation (MF/012879/2025-724) and introduced a new 2025 corporate income tax return form, which includes a redesigned “Table I
See MoreAustralia: Federal Court pauses Oracle royalty tax case to permit treaty arbitration with Ireland
The Full Federal Court of Australia ruled in favour of Oracle, allowing its Mutual Agreement Procedure with Ireland to proceed by staying domestic tax proceedings, reaffirming taxpayers’ treaty rights to prevent double taxation over intra-group
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Hungary: National Assembly automatic exchange of information on crypto-assets, financial accounts, digital platform income
Hungary’s National Assembly ratified three OECD agreements—CARF MCAA, CRS MCAA Addendum, and DPI-MCAA—to enhance automatic exchange of information on crypto-assets, financial accounts, and digital platform income Regfollower
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Slovenia: FURS announces CbC filing deadline for 2024 reports
Reporting entities must submit CbC reports in accordance with the delivery instructions published in Annex 21 of the Rules Amending the Rules on the Implementation of ZDavP-2 (Official Gazette of the Republic of Slovenia, Nos. 30/17, 37/18 and
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European Commission unveils 2026 work programme, signalling withdrawal of key tax proposals
EU unveiled 2026 plan on 21 October 2025 to boost sovereignty, security, and competitiveness. The European Commission has presented its 2026 work programme, outlining a series of initiatives aimed at strengthening Europe’s sovereignty,
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UN Tax Committee progresses on extractives, digital tax, transfer pricing initiatives
The UN Tax Committee reviewed proposals to establish new workstreams on extractive industries, digital economy, and transfer pricing—aiming to enhance guidance on critical minerals valuation, digital services and remote work taxation, and transfer
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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
See MoreAustralia: 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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