Posts by: RF Report


Singapore: IRAS revises e-tax guide on hybrid instrument taxation

The Inland Revenue Authority of Singapore (IRAS) has released the third edition of its e-Tax Guide on the Income Tax Treatment of Hybrid Instruments on 26 December 2025.  The guide outlines how hybrid instruments are classified as debt or equity for tax purposes. Key updates in this edition include: Clarification on how the Comptroller of...

Argentina implements the BEPS MLI

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) entered into force for Argentina on 1 January 2026. Argentina signed the convention on 7 June 2017 and deposited its final MLI Position on 29 September 2025, identifying 17 tax treaties to be covered by the MLI. For a tax treaty to...

Malaysia: IRBM defers e-invoicing for new businesses, exempts sub-MYR 1 million revenue taxpayers

The Inland Revenue Board of Malaysia (IRBM) has released an updated guidance on 7 December 2025, where it revised the annual turnover threshold for e-invoicing. In a previous report, taxpayers with annual turnover or revenue below MYR 500,000 were exempt from e-invoicing. However, under the updated e-Invoice implementation timeline, this exemption has been adjusted to...

China unveils new implementation regulations for VAT law

China’s State Council has released the Regulations for the Implementation of the Value-Added Tax (VAT) Law on 30 December 2025, marking a significant milestone in the nation’s fiscal modernisation. The VAT Implementation Regulations (VATIR) comprise six chapters and 54 articles and are designed to define key terms and clarify the new VAT Law, ensuring consistent...

Amending protocol to tax treaty between Norway, Qatar enters into force

In an update, Norway’s government clarified that the protocol amending the 2009 income tax treaty between Norway and Qatar entered into force on 4 September 2025. The amendments modernise the treaty in line with OECD BEPS standards and strengthen anti–tax avoidance provisions. Signed on 4 September 2024, this is the first amendment to the treaty...

Italy gazettes state budget for 2026

Italy’s government has gazetted Law No. 199 of 30 December 2025 on the State Budget for 2026. The main tax measures include: The financial sector will face higher taxation, with new levies on banks, insurers, and financial operators expected to generate EUR 5–6 billion in 2026. This includes doubling the Tobin Tax on financial transactions,...

Malaysia: IRBM updates ruling on tax classification for SMEs

The Inland Revenue Board of Malaysia (IRBM) released Public Ruling No. 8/2025 on 22 December 2025, providing guidance on the classification and tax treatment of micro, small, and medium-sized companies or enterprises (MSMEs), including limited liability partnerships (LLPs). The objective of this Public Ruling (PR) is to provide an explanation of the specific criteria and...

US: IRS updates guidance on business interest deduction limits

The US Internal Revenue Service (IRS) updated the frequently asked questions in Fact Sheet 2025-09 on 23 December 2025, regarding changes to the limitation on the deduction for business interest expense (Section 163(j)) under the One, Big, Beautiful Bill. For tax years beginning after 31 December 2024, OBBB amended Section 163(j) by: Allowing taxpayers to...

Chile: SII clarifies income tax treatment, VAT on services by foreign companies 

Chile’s tax authority (SII) has issued Letter Ruling No. 2627 of 18 December 2025, clarifying the VAT and income tax treatment of services supplied by a foreign entity in Chile. SII has clarified the Value Added Tax (VAT) treatment for services supplied in Chile by foreign companies, using the example of a Spanish company providing...

Montenegro: Parliament adopts BEPS MLI

Montenegro’s parliament adopted the draft law ratifying the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 27 December 2025. Once the internal ratification process is complete, Montenegro will deposit its instrument of ratification, bringing the MLI into force for the covered tax treaties. Earlier, Montenegro’s government adopted...