OECD updates BEPS Action 5 transparency framework on tax rulings
OECD updated BEPS Action 5 rules with new peer review terms and XML Schema for 2027. The OECD released a set of revisions to the BEPS Action 5 minimum standard on the spontaneous exchange of information on tax rulings (the “transparency
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South Africa: National Treasury withdraws amendment on hybrid equity instruments
National Treasury has retracted its proposal to amend the definition of “hybrid equity instrument” in section 8E of the Income Tax Act following industry concerns. South Africa's National Treasury confirmed that the proposal in the 2025 draft
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Switzerland: National Council approves CARF MCAA, Addendum to CRS MCAA
National Council approves CARF MCAA and CRS MCAA Addendum for enhanced tax information exchange. Switzerland’s National Council (Nationalrat) approved the Multilateral Competent Authority Agreement under the Crypto-Asset Reporting Framework
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Costa Rica: DGT extends filing deadline for transfer pricing informative statements for 2024
Resolution MH-DGT-RES-0043-2025 extends the initial transitional deadline to 31 March 2026 for the 2024 fiscal year. Costa Rica’s Tax Administration (DGT) has published Resolution No. MH-DGT-RES-0043-2025 in the Official Gazette on 5
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Australia strengthens beneficial ownership transparency, expands small business asset deductions
The key measures focus on improved beneficial ownership disclosure for listed entities and the extension of the instant asset write-off for small businesses. The Treasury Laws Amendment (Strengthening Financial Systems and Other Measures) Bill
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Australia, New Zealand agree on arbitration framework under BEPS MLI
The Memorandum of Arrangement sets out rules for arbitration requests, required information, arbitrator appointments, and the overall arbitration process. The Australian Taxation Office (ATO) and New Zealand signed a Memorandum of Arrangement
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OECD releases updated signatory list for GIR MCAA
Switzerland is the latest signatory to join the GIR MCAA. The OECD has released the list of 16 countries that have signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) as of 19 September
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Switzerland signs up for GIR MCAA
Switzerland signed the GIR MCAA, joining 15 other jurisdictions to facilitate standardised GloBE information exchange for MNE Groups. According to an OECD update released on 4 September 2025, Switzerland signed the Multilateral Competent
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OECD extends comment period on copper pricing toolkit
The deadline for submitting comments has been extended to 17 September 2025. The OECD announced an extension for public comments on its draft toolkit in August 2025, designed to help developing countries address transfer pricing challenges in
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Poland: Ministry of Digital Affairs to further consult on proposed digital services tax
The meeting will be held on 17 September at the Ministry of Digital Affairs. Poland’s Ministry of Digital Affairs announced on 1 September 2025 that it will host another series of meetings devoted to consultations on the introduction of a
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Zambia: Supreme Court rules in ZRA v. Nestlé transfer pricing case
Zambia’s Supreme Court upholds ZRA’s transfer pricing audit on Nestlé Zambia, confirming low-risk distributor status and reinstating a ZMW 13.8 million tax assessment. The Supreme Court of Zambia delivered its decision on transfer pricing in
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Peru to implement BEPS multilateral instrument
Peru will implement the BEPS Multilateral Instrument from 1 October 2025, with application to tax treaties depending on counterparties’ ratifications. Peru’s Ministry of Foreign Affairs published a notice on 23 August 2025 in a special
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OECD publishes updated signatory list for GIR MCAA
The latest signatories now include the Netherlands, Austria, Belgium, Denmark, France, Ireland, Italy, Japan, Luxembourg, New Zealand, Portugal, the Slovak Republic, South Korea, Spain, and the UK. The OECD has released the list of 15 countries
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Switzerland clarifies application of hybrid arbitrage arrangements under transitional CbCR Safe Harbour
SFTA confirmed that OECD guidance on hybrid arbitrage arrangements under the transitional CbCR safe harbour applies in Switzerland only to transactions entered into after 18 December 2023. The Swiss Federal Tax Administration (SFTA) has issued
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UAE signs multilateral agreement on crypto asset tax reporting
The UAE has signed the OECD’s Multilateral Competent Authority Agreement under the Crypto-Asset Reporting Framework, joining 51 countries in standardising automatic tax information exchange for crypto transactions. The UAE signed the
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Netherlands joins GIR MCAA
As of the OECD update of 26 August 2025, the GIR MCAA has been signed by 15 jurisdictions. The Netherlands has signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA), under Pillar Two of the OECD/G20
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Denmark: Transfer Pricing documentation submission deadline set for FY 2025
Danish companies must submit comprehensive transfer pricing documentation, including master and local files and intercompany agreements, within 60 days of their corporate tax return to comply with section 39 of the Danish Tax Control
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Poland: MoF announces measures to combat aggressive transfer pricing strategies
The new measures assist the National Tax Administration in detecting and countering large corporations that evade or underreport their income tax. Poland’s Ministry of Finance has announced two new measures on 19 August 2025, to tackle
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