Posts by: RF Report


Germany, Netherlands tax treaty protocol enters into force

The amending protocol to the 2012 tax treaty between Germany and the Netherlands will enter into force on 31 December 2025. The Netherlands and Germany signed the protocol on 14 April 2025. It will take effect starting 1 January 2026. The treaty between the two countries seeks to eliminate double taxation and prevent tax evasion....

Korea (Rep.) issues 2025 MAP guidelines for international tax disputes

Korea (Rep.)’s National Tax Service (NTS) on 18 December 2025 published online the 2025 Guidelines for Requesting Mutual Agreement Procedure (MAP) Assistance, providing a comprehensive framework for resolving international tax disputes with treaty partners. The guidance explains how taxpayers can seek relief from double taxation or inconsistent treaty interpretations through formal consultations between competent authorities....

Azerbaijan releases consolidated text of tax treaty with Bosnia and Herzegovina under BEPS MLI 

Azerbaijan’s State Tax Service (STS) has released the consolidated versions of its tax treaty with Bosnia and Herzegovina, reflecting the changes introduced by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). These consolidated texts have been prepared based on the reservations and notifications submitted to the...

Azerbaijan releases consolidated text of tax treaty with Belgium under BEPS MLI 

Azerbaijan’s State Tax Service (STS) has released the consolidated versions of its tax treaty with Belgium reflecting the changes introduced by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). These consolidated texts have been prepared based on the reservations and notifications submitted to the Depositary by...

Azerbaijan releases consolidated text of tax treaty with Austria under BEPS MLI 

Azerbaijan’s State Tax Service (STS) has released the consolidated versions of its tax treaty with Austria reflecting the changes introduced by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The consolidated texts have been prepared based on the reservations and notifications submitted to the Depositary by...

Italy gazettes decree transposing DAC8 crypto-asset reporting, exchange of data

Italy has published Legislative Decree No. 194/2025 in the Official Gazette No. 296 of 22 December 2025, which implements the Amending Directive to the 2011 Directive on Administrative Cooperation (2023/2226) (DAC8). The measure implements the DAC8 directive, introducing reporting requirements and the automatic exchange of data on crypto-asset transactions by operators, thus expanding the scope...

Taiwan: MoF extends electric vehicle tax exemption until 2030

Taiwan’s Ministry of Finance (MoF) states that in order to enhance the willingness of consumers to purchase completely electric-operated automobiles or motorcycles , the Legislative Yuan passed on its third reading the draft of the amendment to Article 12-3 of the Commodity Tax Act submitted by the Executive Yuan for review by the Legislative Yuan,...

Taiwan: Taipei Tax Bureau clarifies certain share, capital contribution transactions to be taxed as real estate deals

Taiwan’s The Taipei National Taxation Bureau of the Ministry of Finance stated that, in order to prevent individuals and profit-making enterprises from effectively transferring the real estate and land within China of the invested profit-making enterprises through the transaction of shares or capital contributions of domestic and foreign profit-making enterprises under their control, thereby evading...

Lithuania: VMI updates VAT guidance for financial services ahead of 2026 changes

Lithuania’s State Tax Inspectorate (VMI) has issued updated guidance on Article 28 of the Law on VAT, clarifying the application of VAT exemptions for financial services. The revisions introduce a new “technical/administrative services” rule under Article 28(9), specifying that purely administrative, physical, technical, or similar services that do not alter the legal or financial position...

Hong Kong: IRD adjusts interest on tax reserve certificates

The Hong Kong Inland Revenue Department (IRD) announced, on 24 December 2025, that starting from 5 January 2026, the new annual rate of interest payable on Tax Reserve Certificates will be 0.2417% against the current rate of 0.2583%, i.e. the new rate will be HKD 0.0201 per month per HKD 100. Tax Reserve Certificates bear...