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
See MoreOECD: 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 entitlementÂ
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
See MoreOECD: 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 instrumentÂ
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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Czech Republic revises jurisdictions subject to automatic financial information exchange
The list covers 159 jurisdictions, detailing the instruments for information exchange—such as the Mutual Assistance Convention, EU Council Directive 2014/107 (DAC2), and bilateral tax treaties—along with whether each jurisdiction has signed the
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South Africa: SARS consults draft rules for CARF implementation, CRS amendments
The consultation concludes on 3 October 2025. South Africa’s National Treasury and the South African Revenue Service (SARS) introduced draft regulations on 15 September 12025, aimed at enhancing the country's approach to cryptoasset oversight
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Cyprus:Â FY 2024 CbC report, FY 2025 CbC notification submission deadline set for December
MNE groups must submit CbC reports for the 2024 fiscal year if their year-end is 31 December 2024, as well as CbC notifications for the 2025 fiscal year if their year-end is 31 December 2025. MNE groups in Cyprus must submit country-by-country
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UAE: MoF signs CARF agreement to share crypto tax data, opens public consultation
The consultation ends on 8 November 2025. The UAE’s Ministry of Finance ( MOF) has signed the Multilateral Competent Authority Agreement on the Automatic Exchange of Information under the Crypto-Asset Reporting Framework (CARF), following its
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Senegal: DGID suspends CbC reporting obligations for FY 2023, 2024
Multinational enterprises with operations in Senegal are not obliged to file country-by-country reports (CbCR) for the FY 2023-2024. Senegal’s tax administration, the Directorate General of Taxes and Domains (DGID), announced in a social
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OECD publishes 2025 peer review compilation on CbC reporting
The OECD peer review report covers 142 jurisdictions that have submitted legislation or information on the implementation of CbC reporting. The OECD has released the Compilation of 2025 Peer Review Reports on Country-by-Country Reporting on 23
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