Posts by: RF Report


Hungary consults draft decree to advance global minimum tax

Hungary’s Ministry for National Economy initiated a public consultation on a draft ministerial decree on 13 December 2025 to establish the detailed implementation rules for reporting, filing, and payment obligations under the global minimum tax (Pillar 2)  for large multinational and domestic corporate groups. The draft decree details mandatory registration and reporting requirements, including the...

Australia: ATO announces GIC, SIC rates for Q3 2025-26

The Australian Taxation Office (ATO) announced the general interest charge (GIC) rates and shortfall interest charge (SIC) rates for the third quarter of the 2025-26 income year on 9 December 2025. For the quarter commencing on 1 January 2026, the GIC annual rate is set at 10.65%, and the SIC annual rate is set at...

Luxembourg implements 2026 Budget Bill

Luxembourg has enacted the 2026 budget bill following its adoption by parliament. The full budget bill was published in the Official Gazette on 19 December 2025. The government has finalised the Law of 19 December 2025, introducing targeted changes to personal income taxes and excise duties for the 2026 fiscal year, with a focus on...

Argentina: ARCA raises transfer pricing reporting thresholds

Argentina’s Federal Tax Administration (ARCA) has increased the revenue thresholds that trigger mandatory transfer pricing documentation, aiming to streamline reporting requirements for multinational and local taxpayers. The changes are set out in General Resolution 5798/2025, published in the Official Gazette on 16 December 2025. Reporting Type Previous Threshold New Threshold Notes International intermediaries (Article 41,...

Egypt: MoF increases transfer pricing documentation threshold

Egypt’s Ministry of Finance (MoF) has issued Minister of Finance Decision No. 534 of 2025 of 17 December 2025, revising the rules for transfer pricing (TP) documentation. Under the decision, the annual related-party transaction threshold for TP reporting has been raised to EGP 30 million from EGP 15 million. Companies with transactions below this level...

Japan, Kyrgyzstan sign new income tax treaty

Japan and Kyrgyzstan signed a new tax treaty on 19 December 2025 to eliminate double taxation on income and strengthen measures against tax evasion and avoidance. The treaty updates rules on the taxation of business profits and investment income, introduces anti-abuse provisions, and reinforces the exchange of information between tax authorities. Both governments said the...

Taiwan: Tax Bureau orders business operators to include tax in pricing, warns against extra charges

Taiwan’s Northern District National Taxation Bureau of the Ministry of Finance stated that when business operators sell goods or services, the pricing of taxable items must include business tax. In addition, uniform invoices must be issued in accordance with the prescribed time limits for issuing sales certificates. Business operators may not require consumers to pay...

South Africa: SARS to launch global minimum tax registration on efiling in March 2026

The South African Revenue Service (SARS) will roll out registration and notification functionality for the Global Minimum Tax (GMT) through its eFiling platform on 16 March 2026. This announcement was made on 19 December 2025. The move forms part of South Africa’s implementation of the Global Anti-Base Erosion (GloBE) framework. SARS said the integration of...

Taiwan: Tax Bureau clarifies R&D investment tax credit rules

Taiwan’s Northern Taiwan National Taxation Bureau of the Ministry of Finance has stated that research and development (R&D) expenditures eligible for investment tax credits must be traceable, while routine testing costs are excluded from the scope of deductions. This announcement was made on 19 December 2025. The Bureau explained that under Article 10 of the...

Russia: Government approves list of budget expenditures using digital ruble

Russia’s government has approved a list of budget expenditures eligible for execution with the use of the digital ruble beginning in 2025. This announcement was made on 18 December 2025. The list was developed under Federal Law No. 303-FZ of July 31, 2025, “On Amendments to the Budget Code of the Russian Federation”, which provides...