Tuesday, March 17, 2026
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’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’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...
The Hong Kong Inland Revenue Department has released updated and new FAQs on the 2006 income tax arrangement with Mainland China, including revisions related to the determination of individual residence. Updated questions Question 1: According to the Comprehensive Arrangement, under what circumstances will a Hong Kong resident working in the Mainland be exempted from paying...
Qatar’s General Tax Authority (GTA) announced on 31 December 2025 that the tax return filing period for the financial year ended 31 December 2025 will run from 1 January 2026 to 30 April 2026. This comes in compliance with the provisions of Income Tax Law No. (24) of 2018, its Executive Regulations, and their amendments....
The Inland Revenue Authority of Singapore (IRAS) has issued the Multinational Enterprise (Minimum Tax) (Administrative Matters) Regulations 2025 (Administrative Regulations) on 29 December 2025, which entered into force on 31 December 2025. This legislation provides new guidance on registration for the multinational enterprise top-up tax and domestic top-up tax. Registration for Multinational Enterprise Top-up Tax and...
Bahrain’s National Bureau for Revenue (NBR) has updated its frequently asked questions (FAQs) on the Domestic Minimum Top-up Tax (DMTT), which applies from 1 January 2025. The DMTT introduces a 15% minimum tax on large multinational enterprise (MNE) groups operating in Bahrain with consolidated group revenue of at least EUR 750 million in at least...
Thailand’s Revenue Department announced that the Cabinet approved draft secondary legislation on 30 December 2025 to implement the Emergency Decree on Top-up Tax B.E. 2567 (2024). These draft instruments set out detailed rules for determining the scope of multinational enterprise (MNE) groups subject to the Top-up Tax, as well as for the adjustment of income,...
The Israeli parliament (Knesset) approved the Corporate Minimum Tax for Multinational Groups Law in its second and third readings, implementing the OECD’s Pillar 2 rules into domestic legislation on 29 December 2025. The legislation incorporates the OECD’s Qualified Domestic Minimum Top-up Tax (QDMTT) into Israeli law. Under the new rules, multinational enterprises with consolidated global...
The UAE Federal Tax Authority (FTA) has released a new Corporate Tax Guide on Advance Pricing Agreements (CTGAPA1) in December 2025. The guide outlines the procedural framework for APAs and covers an overview of the APA programme, applicable procedures, and the monitoring and review process. Transfer Pricing (“TP”) provisions were introduced in the UAE along...