The European Commission, in a notice on 12 January 2026, acknowledged the Side-by-Side arrangement on Safe Harbours and confirmed its application within the framework of Council Directive (EU) 2022/2523 (Pillar 2 Directive). Under Article 32 of the Directive, Member States may allow, at the option of the filing constituent entity, the top-up tax for a...
Hungary has adopted revised transfer pricing documentation rules under Decree No. 45/2025, published in the Official Gazette on 23 December 2025. The revised rules will require taxpayers to reassess their compliance approach ahead of the 2026 fiscal year. Scope and application The new regulation reshapes Hungary’s domestic transfer pricing documentation framework, affecting documentation thresholds, eligible...
Estonia’s Ministry of Finance has confirmed that the income and capital tax treaty between Estonia and Liechtenstein entered into force on 26 December 2025. Signed on 10 July 2025, the agreement seeks to eliminate double taxation and prevent tax evasion. The treaty covers Estonian income tax, Liechtenstein’s corporate income tax, personal income tax, real estate...
Korea (Rep.)’s National Tax Service (NTS) has issued a revised version of its guidance on the Mutual Agreement Procedure (MAP) for taxpayers. The document provides details on MAP applications, the procedure and conclusion of cases, implementation of MAP results, statistical data, and required documentation. The term “mutual agreement procedure” means the procedure by which interpretation...
Greece’s Independent Authority for Public Revenue (AADE) has issued a decision establishing the framework for a special VAT regime for businesses based in other European Union (EU) Member States. The regime allows non-established enterprises to benefit from the small enterprise exemption for transactions taxable in Greece. To qualify, businesses must have notified their EU Member...
The income tax treaty between Gabon and Italy, signed on 28 June 1999, entered into force on 19 December 2025. The agreement applies to Gabon’s corporate tax, flat-rate minimum tax, individual income tax, and tax on income from immovable property, as well as Italy’s corporate and individual income taxes. The treaty sets withholding tax rates...
Sri Lankan Inland Revenue Department (IRD) has reminded taxpayers to pay Advance Income Tax (AIT), Withholding Tax (WHT) and Advance Personal Income Tax (APIT) withheld during December 2025 no later than 15 January 2026. Tax Types and Payment Codes Tax Type Code Payment Period Code Category AIT/WHT on Interest 43 25120 S AIT/WHT on Fees...
A new income and capital tax treaty between Romania and the UK, signed on 13 November 2024, entered into force on 22 December 2025, replacing the 1975 treaty. The agreement covers Romanian income and profit taxes, as well as UK income tax, corporation tax, and capital gains tax. Key provisions include reduced withholding tax rates:...
Argentina has increased the thresholds for tax evasion and aligned the statute of limitations with civil and commercial regulations under Law 27,799, which was published in the Official Gazette on 2 January 2026. Law 27,799 introduces a comprehensive overhaul of the Tax Criminal Regime and tax procedure laws in Argentina. The legislation focuses on updating...
The Colombian Tax and Customs National Authority (DIAN) issued Resolution No. 000238 on 15 December 2025, setting the Tax Value Unit (Unidad de Valor Tributario – UVT) for 2026 at COP 52,374. This is an increase from COP 49,799 in 2025. The UVT is a standard measure used across Colombia’s tax system. It determines thresholds...