Posts by: RF Report


France gazettes special budget law for 2026, ensures uninterrupted functioning of government operations

France’s government has published Law No. 2025-1316 of 26 December 2025 in the Official Gazette on 27 December 2025, authorising the State to continue collecting existing taxes to ensure the uninterrupted functioning of government operations until the Finance Law for 2026 takes effect. The Law enumerates over EUR 45 billion in specific financial transfers allocated...

Portugal extends deadline for Global Minimum Tax filing

Portugal has extended the deadline for submitting the Registration Declaration (Modelo 62) under the Global Minimum Tax (GMT) regime. The extension is outlined in Order No. 158/2025 – XXV of 12 December 2025. The extension applies to entities whose fiscal years ended between 31 December 2024 and 31 March 2025. They can now submit the...

Belgium updates transfer pricing documentation rules

Belgium published the Royal Decree of 7 December 2025 in the Official Gazette on 19 December 2025, which repeals the previous Royal Decree of 16 June 2024 concerning transfer pricing documentation. Under the new decree, taxpayers are no longer required to attach full transfer pricing studies to the Local File (Form 275-LF). The update aligns...

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,...