New Zealand, Slovenia sign income tax treaty
New Zealand and Slovenia have signed an income tax treaty on 3 December 2024. A tax treaty is a bilateral agreement between two countries designed to address issues related to the double taxation of both passive and active income of their
See More
Austria updates CFC rules to prevent double taxation under Pillar Two
Austria's parliament has amended its CFC rules to avoid double taxation issues under the Pillar Two global minimum tax framework. Amendments to Section 10a of the Austrian Corporate Income Tax Act have been approved and now require that Qualified
See More
Hungary publishes updated GloBE data sheet
Hungary’s Tax and Customs Agency has released the updated version of the GloBE data sheet on 5 December 2024. The data sheet features technical enhancements and detailed field definitions to simplify XML completion and includes a User
See More
Moldova ratifies tax treaty protocol with Slovak Republic
Moldova published Decree No. 1676 of 3 December 2024 in the Official Gazette on 5 December 2024, enacting the law ratifying the amending protocol to the 2003 income and capital tax treaty with the Slovak Republic. The agreement between the Slovak
See More
Poland: Ministry of Finance designates Head of the Kujawsko-Pomorskie Tax Office as authority for global tax compliance
The Polish Ministry of Finance has announced designating the Head of the Kujawsko-Pomorskie Tax Office in Bydgoszcz as the sole authority responsible for matters related to the global minimum tax. This decision, outlined in a draft regulation
See More
San Marino ratifies DTA, amending protocol with Netherlands, Malta, Lithuania
The Sammarinese Official Gazette published Decree No. 184/2024, 185/2024, and 186/2024 on 28 November 2024 ratifying the Double Taxation Agreement (DTA) with the Netherlands, the third protocol to the Double Taxation Agreement (DTA) with Malta and
See More
Ireland: Revenue clarifies interest deduction restrictions for intercompany loans
The Irish Revenue Commissioners released eBrief No. 289/24 on 27 November 2024, clarifying restrictions surrounding interest deductions for intercompany loans. The update explains which subsidiary companies are no longer able to claim deductions
See More
Bulgaria: Parliament considers corporate tax amendments to implement GloBE rules, extend certain tax exemptions
Bulgaria’s Council of Ministers has submitted a proposal to parliament for amendments to the Corporate Income Tax Act, focusing on refining Global Anti-Base Erosion (GloBE) rules and extending regional tax relief measures on 2 December
See More
Italy ratifies new tax treaty with China
Italy has published Law No. 182 of November 18, 2024, in the Official Gazette on 3 December, 2024, ratifying the new tax treaty with China. The agreement aims for the elimination of double taxation with respect to taxes on income and the prevention
See More
Serbia ratifies amending protocol to tax treaty with Hungary
Serbia has published the Law of 11/28/24 in its Official Gazette ratifying the pending protocol to the 2001 income and capital tax treaty with Hungary on 3 December 2024. Earlier, Hungary and Serbia signed an amending protocol to the
See More
Belgium proposes updates to DAC6, DAC7 rules
Belgium’s government has introduced a draft law proposing updates to the current regulations on the automatic exchange of information (AEOI) and related obligations. The draft legislation also outlines new penalties under DAC6 and DAC7. These
See More
Netherlands: Amount B will not be introduced for Dutch taxpayers
The Netherlands government has announced, on 4 December 2024, in a decree that it will not be adopting the OECD’s new transfer pricing rules (Amount B). However, it will acknowledge other countries' adoption of the OECD's new transfer pricing
See More
EU proposes permanent digital trade certificates with Turkey
The European Union (EU) proposed a new measure to solidify the use of electronic A.TR movement certificates in its customs partnership with Turkey on 29 November 2024. Originally introduced during the COVID-19 pandemic as a temporary solution to
See More
Ireland: Revenue revises guidance on Interest Limitation Rule
Irish Revenue has published eBrief No. 292/24 updated guidance on the Interest Limitation Rule on 29 November 2024. This includes revisions to sections 8 and 9 of the guidance, reflecting changes introduced by the Finance Act 2024. In sections 8
See More
Bulgaria: National Assembly reviews VAT Act amendments to align with EU small business scheme
Bulgaria's National Assembly is reviewing a draft bill, presented on 2 December 2024, to amend the Value Added Tax (VAT) Act to implement the EU small business scheme for cross-border supplies. The draft bill is under parliamentary review and
See More
Argentina, Slovenia consider signing income tax treaty
In a LinkedIn post, Slovenia’s Minister of Finance, Klemen Boštjančič, stated that officials from Argentina and Slovenia convened recently to negotiate an income and capital tax treaty between the two countries. Double tax treaties (DTTs)
See More
Portugal approves Budget Bill 2025Â
Portugal’s parliament has approved the Budget Bill 2025 on 29 November 2024. The President will promulgate the 2025 Budget Bill, after which the corresponding law will be officially published. Earlier, Portugal’s Finance Minister submitted
See More
European Commission issues final rules for CbC reporting directive
The European Commission has published the final version of the Commission Implementing Regulation (EU) 2024/2952 of 29 November 2024 in the Official Journal of the EU on 2 December 2024. This document establishes a common template and electronic
See More