Posts by: RF Report


Taiwan: MoF clarifies tax treaty rules for foreign digital service providers

Taiwan’s Ministry of Finance has clarified on 5 December 2025 that foreign e-commerce providers selling to Taiwanese companies may qualify for reduced or exempt withholding tax under applicable tax treaties. To claim benefits, providers must submit an official application with supporting documents, and any tax withheld before approval can be refunded afterwards. Overseas e-commerce businesses...

South Africa consults REIT qualification of unlisted companies

South Africa’s National Treasury and the Revenue Service (SARS), on 11 December 2025, published a draft notice outlining requirements for unlisted companies to qualify as real estate investment trusts (REITs). The rules follow the 2024 Taxation Law Amendment Act, which expanded the REIT definition to include unlisted South African companies that meet specific criteria set...

OECD recommends 26 nations to enhance tax ruling transparency

The OECD has issued a report calling on 26 countries to improve how they provide tax rulings, which help authorities assess risks and tackle base erosion and profit shifting. In total, the organisation made 46 recommendations to improve these processes. Meanwhile, 113 other countries were found to fully comply with the OECD’s minimum standard for...

Lithuania amends DAC7 rules

Lithuania’s State Tax Inspectorate (VMI) adopted amendments to Order No. VA-95 on 12 December 2025, which regulates reporting of platform-based activities. The changes implement requirements under the Amending Directive to the 2011 Directive on Administrative Cooperation (2021/514) (DAC7). The amendments align DAC7 reporting with the latest Amending Directive to the 2011 Directive on Administrative Cooperation...

France: DGFiP extends POS software certification deadline

France’s Ministry of Finance (DGFiP) has extended the deadline for mandatory certification of point of sale (POS) and cash register software to 1 September 2026. The extension allows certification bodies more time to process applications and gives software vendors additional time to update their systems in line with new anti-fraud requirements and upcoming e-invoicing rules....

Belarus, Jordan sign income tax treaty

Belarus and Jordan signed an income tax treaty during the Belarus-Africa Forum in Moscow on 16 December 2025. The agreement seeks to eliminate double taxation on income and prevent tax evasion between Belarus and Jordan. Before the signing, the President of Belarus issued Decree No. 433 on 15 December 2025, formally authorising the Ministry of...

UK ratifies new tax treaty with Romania

The UK has ratified the new income and capital tax treaty with Romania through the Double Taxation Relief and International Tax Enforcement (Romania) Order 2025 on 10 December 2025. The treaty, originally signed on 13 November 2024, will replace the existing 1975 agreement. Key provisions on the mutual agreement procedure, information exchange, and assistance in...

France updates list of companies subject to financial transaction tax

French tax authorities have updated the list of companies subject to the financial transaction tax (FTT) under Article 235 ter ZD of the General Tax Code on 17 December 2025. The update applies to French companies whose securities are traded on regulated markets and whose market capitalisation exceeds EUR 1 billion as of 1 December...

Denmark: Parliament approves temporary electricity tax relief

Denmark’s Parliament (Folketinget) passed Bill L 24 on 16 December 2025, reducing the general electricity tax to the European Union minimum rate for 2026 and 2027. The move follows the government’s 2026 Finance Bill and aims to provide Danes with greater disposable income amid rising food prices. Under the legislation, the electricity tax will drop...

Hungary ratifies GIR MCAA

Hungary published Act XC of 2025 in the Official Gazette on 16 December 2025, ratifying the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA). Hungary joined the GIR MCAA, under Pillar 2 of the OECD/G20 Inclusive Framework’s two-pillar solution on 31 October 2025. The Global Anti-Base Erosion (GloBE) Model Rules require...