BEPS
KPMG TaxNewsFlash reports about OECD's base erosion and profit shifting (BEPS) initiative and tax transparency
News
Poland: Certain EU non-cooperative jurisdictions not included in list of countries applying harmful tax competition
Countries and territories on EU list of non-cooperative jurisdictions, but not Poland’s list
March 19, 2025
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Italy: Ministerial Decree on GloBE information return (GIR) notifications
The actual notification form and further details on the submission will be clarified by the revenue agency.
March 18, 2025
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Bahrain: Updated domestic minimum top-up tax (DMTT) registration manual
Version 1.0 released on March 9, 2025
March 17, 2025
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India: Clarification to guidance that grandfathering provisions in tax treaties are excluded from principal purpose test
Guidance does not affect application of other treaty provisions or anti-abuse rules
March 17, 2025
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Turkey: Announcement that Amount B under Pillar One will not be applied
Official announcement on March 7, 2025
March 17, 2025
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Mongolia: MLI effective January 1, 2025; other direct and indirect tax developments
Including tax incentives for corporate socially responsible investments
March 13, 2025
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EU: Council reaches political agreement on DAC9
Member states need to implement the directive into national legislation by December 31, 2025.
March 11, 2025
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Cameroon: Guidelines for local country-by-country declarations
Content, format, and procedures for filing local CbC declarations
March 6, 2025
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Indonesia: Implementation of global minimum tax
Enforcement of global anti-base erosion (GloBE) rules from January 1, 2025
March 5, 2025
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OECD: BEPS Action 14 MAP peer review results
Progress in making dispute resolution more effective under the BEPS package
March 5, 2025
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UAE: FAQs on Pillar Two domestic minimum top-up tax
Ministry of Finance published a list of “frequently asked questions”
March 4, 2025
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Latest tax developments from the United States and from KPMG member firms around the globe
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OECD: Report to G20 Finance Ministers and Central Bank Governors, recent developments in international tax cooperation
Recent developments include implementation of BEPS minimum standards and Two-Pillar solution
February 27, 2025
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Slovakia: Proposed amendments to implement exchange of Pillar Two information between EU member states (DAC9)
Minister of Finance announced amendments on January 20, 2025
February 27, 2025
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Denmark: Proposed amendments to Pillar Two law
Comments are due by March 3, 2025.
February 26, 2025
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EU: Public meeting of European Parliament Subcommittee on Tax Matters with European Commissioner responsible for tax
EU will not withdraw from Pillar Two agreement and remains committed to reaching Pillar One agreement
February 26, 2025
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Poland: Proposed amendments to mandatory disclosure rules (DAC6)
The government is expected to adopt the proposed amendments in the second quarter of 2025.
February 26, 2025
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Taiwan: Updated list of low-tax jurisdictions
Effective December 27, 2024
February 25, 2025
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OECD: Consolidated report on Amount B
Incorporates materials on Amount B released from February 2024 until December 2024
February 24, 2025
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Poland: List of jurisdictions with qualified status for Pillar Two purposes
List applies for purposes of local implementation of Pillar Two rules
February 20, 2025
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Vietnam: MCAA for exchange of CbC reports signed; amendments to transfer pricing regulations
Report on recent transfer pricing developments in Vietnam
February 20, 2025
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Australia: Updated form and instructions for thin capitalization test choice
Updated guidance regarding revocation requests
February 14, 2025
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Costa Rica: Proposed amendments to procedures for international tax information exchange
Proposed amendments include enhancing frameworks for automatic exchange of tax information
February 14, 2025
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Spain: Public country-by-country reporting obligations
Overview of public CbC reporting obligations in Spain
February 14, 2025
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Kenya: Legislation replacing digital services tax with significant economic presence tax, implementing Pillar Two rules
Legislation also includes withholding tax and VAT changes
February 13, 2025
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Sweden: Government report to Parliament on EU proposal for exchange of Pillar Two information between EU member states (DAC9)
Report regarding changes potentially required for implementation in Sweden
February 13, 2025
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Uruguay: Updated list of low or no tax jurisdictions
Updated list effective January 1, 2025
February 13, 2025
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UAE: Legislation implementing Pillar Two global minimum tax rules
Effective for financial years beginning on or after January 1, 2025
February 12, 2025
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France: Tax measures in Finance Act 2025
Includes direct and indirect tax measures affecting companies
February 11, 2025
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Ireland: Updated guidance regarding controlled foreign company (CFC) rules
Incorporating changes from the Finance Act 2024
February 7, 2025
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Italy: List of jurisdictions with transitional qualified status for Pillar Two purposes
List applies for purposes of local implementation of Pillar Two rules
February 7, 2025
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Netherlands: Updated list of non-cooperative tax jurisdictions
Updated list effective as of January 1, 2025
February 7, 2025
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OECD: Public consultation on tax incentives
Comments are due February 11, 2025.
February 7, 2025
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UK: Amendments to Pillar Two rules in amended Finance Bill 2024-2025
Including incorporation of provisions from OECD June 2024 Administrative Guidance
February 7, 2025
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OECD: Preferential tax regimes under BEPS Action 5
Latest peer review results
February 6, 2025
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UK: Consultation on supplementary draft guidance on Pillar Two global minimum tax rules
Last consultation before guidance manual will be published in late spring 2025
February 6, 2025
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Germany: Updated list of non-cooperative tax jurisdictions, consultation on draft amendments to Pillar Two rules, changes to transfer pricing rules, other tax developments
Recent tax developments in Germany
January 30, 2025
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Japan: Updated guidance on income inclusion rule
Income inclusion rule was amended in 2024 tax reform
January 29, 2025
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Bahrain: Updated domestic minimum top-up tax registration manual
Updated version of domestic minimum top-up tax registration manual released
January 27, 2025
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France: Form for Pillar Two reporting requirements, country-by-country notification
Pillar Two reporting requirements added to CbC notification form
January 27, 2025
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Australia: Legislation providing details on computation of top-up tax under Pillar Two rules
Rules are effective from January 1, 2024.
January 22, 2025
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South Africa: Legislation implementing Pillar Two global minimum tax rules enacted
Rules are effective for tax years beginning from January 1, 2024
January 22, 2025
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White House announcement on OECD “Global Tax Deal”
A memorandum from President Trump’s White House regarding the OECD “Global Tax Deal”
January 21, 2025
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Cyprus: Implementation of Pillar Two global minimum tax rules and public country-by-country reporting
Implementing laws largely align with EU directives
January 21, 2025
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Bahrain: Guide on entities within scope of domestic minimum top-up tax
Further clarification on various aspects including entities that fall within scope of domestic minimum top-up tax
January 21, 2025
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EU: Tax priorities of Polish Presidency of the Council
Include updating list of non-cooperative jurisdictions for tax purposes and work on DAC9
January 21, 2025
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Thailand: Law implementing Pillar Two global minimum tax rules published
Rules became effective January 1, 2025
January 21, 2025
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KPMG report: Inclusive Framework guidance on application of GloBE rules
Including guidance relating to GloBE information return
January 17, 2025
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KPMG report: Inclusive Framework Administrative Guidance on limitation of the use of deferred tax assets under transitional rules (Article 9.1)
Focuses on the guidance on deferred tax assets under Article 9.1
January 17, 2025
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OECD: Inclusive Framework on BEPS releases updates to global minimum tax administration
Additional administrative guidance under the Pillar Two rules
January 15, 2025
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Spain: Law implementing Pillar Two global minimum tax approved
Law also includes amendments relating to corporate income tax, individual (personal) income tax, VAT, tax on financial entities, and excise duties.
January 15, 2025
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Statement by co-chairs of Inclusive Framework on BEPS indicates still no consensus on Pillar One
The statement indicates that the co-chairs intend to continue working to achieve a consensus on the Amount B Framework and so the overall Pillar One package.
January 13, 2025
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Ireland: Application of Pillar Two global minimum tax rules to fund vehicles and securitization entities
Reports discussing key considerations for fund vehicles and Irish securitization entities
January 9, 2025
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North Macedonia: Parliament adopts law implementing Pillar Two global minimum tax rules
Law aligns with EU minimum tax directive
January 9, 2025
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Poland: Updated list of countries and territories applying harmful tax competition
Updated list became effective January 1, 2025
January 9, 2025
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Oman: Legislation implementing Pillar Two global minimum tax rules
New legislation introduces domestic minimum top-up tax (DMTT) for multinational groups
January 8, 2025
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Kuwait: Legislation implementing Pillar Two global minimum tax rules
New legislation introduces domestic minimum top-up tax (DMTT) for multinational groups
January 8, 2025
Highlighted Insights
BEPS 2.0: Pillar Two
KPMG insights about the impact of the Pillar Two—global minimum tax rules—and how companies are responding
Read more
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Hong Kong: Draft legislation implementing Pillar Two global minimum tax rules
Draft legislation will be presented to the Legislative Council on January 8, 2025.
December 27, 2024
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Ireland: Tax measures in Finance Bill 2024 include Pillar One Amount B rules, amendments to Pillar Two rules
Tax measures effective from November 12, 2024
December 27, 2024
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Japan: Outline of 2025 tax reform proposals, including new Pillar Two rules
Proposals include introduction of undertaxed profits rule (UTPR) and qualified domestic minimum top-up tax (QDMTT)
December 27, 2024
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Luxembourg: Overview of tax measures for 2025, including amended Pillar Two law
Comprehensive overview of the key tax measures for 2025
December 20, 2024
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KPMG report: Proposed adoption of Amount B in the United States
Notice 2025-4 would allow the U.S. application of Amount B—an OECD-initiative to simplify transfer pricing for baseline marketing and distribution activities.
December 19, 2024
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OECD: Fact sheets and pricing tool for implementation of Amount B simplified approach
Fact sheets provide overview of Amount B mechanics, Pricing Automation Tool computes Amount B return for in-scope tested parties
December 19, 2024
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Hungary: Changes to autumn tax package, including Pillar Two rules, agreed by Parliament
Approved version narrows the scope of data that companies subject to global minimum tax are required to report by the end of the year.
December 19, 2024
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Notice 2025-4: Application of Pillar One Amount B simplified and streamlined approach
Treasury and IRS announce intention to issue proposed regulations applicable to tax years beginning on or after January 1, 2025.
December 18, 2024
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Australia: List of specified jurisdictions for public country-by-country reporting
List includes 40 specified jurisdictions
December 18, 2024
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Italy: Guidance on documentation required for special penalty protection for hybrid mismatches
Guidance clarifies contents, deadlines, and methodology of required documentation
December 18, 2024
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Netherlands: Upper house passes entire 2025 Tax Plan package, including amendments to Pillar Two rules
In total, 11 tax bills and an amending act were passed.
December 18, 2024
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OECD: Exchange of information on tax rulings under BEPS Action 5
Eighth annual peer review of the implementation of BEPS Action 5 minimum standard on tax rulings
December 17, 2024
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Australia: Changes to country-by-country reporting exemption process
Changes effective for all exemption requests submitted after January 1, 2025
December 16, 2024
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Bahrain: Pillar Two global minimum tax implementing regulations
The regulations prescribe detailed rules, conditions, and procedures for implementation and enforcement of the Pillar Two global minimum tax.
December 16, 2024
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Gibraltar: Draft legislation implementing Pillar Two global minimum tax rules
Top-up tax would apply for financial years starting on or after December 31, 2023
December 16, 2024
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France: Guidance on Pillar Two global minimum tax filing and notification obligations
Decree specifying Pillar Two filing and notification obligations published on December 5, 2024.
December 12, 2024
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EU: European Court of Auditors report on ATAD, mandatory disclosure rules (DAC6), and tax dispute resolution directive (TDRD)
Report addresses design and implementation of ATAD, DAC6, and TDRD
December 12, 2024
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EU: Final public country-by-country reporting forms published
Implementing regulation effective for financial years starting on or after January 1, 2025
December 12, 2024
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EU: ECOFIN report on various tax initiatives
Report includes updates on Unshell Directive, Transfer Pricing Directive, BEFIT Directive, and DAC9 proposals
December 12, 2024
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Malaysia: Guidance on Pillar Two global minimum tax
The guidance covers scope, filing obligations, transitional penalty relief, and safe harbors.
December 12, 2024
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Australia: Pillar Two minimum tax, public CbC reporting, and foreign residents’ capital gains withholding bills receive Royal Assent
Legislation received Royal Assent on December 10, 2024.
December 11, 2024
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Netherlands: Guidance on how Pillar One Amount B will affect domestic taxpayers
Guidance becomes effective January 1, 2025
December 5, 2024
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KPMG report: Update on future of BEPS guidance from OECD
Noel Maher, Tax Policy Adviser from the OECD, discussed ongoing work at the OECD at KPMG-sponsored conference
December 4, 2024
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Spain: Legislation implementing Pillar Two global minimum tax passed by lower house of Parliament
The legislation also includes amendments relating to corporate income tax, individual (personal) income tax, VAT, tax on financial entities, and excise duties.
December 4, 2024
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Australia: Treasury releases draft legislation for tax treaty with Portugal incorporating BEPS provisions
Consultation on the draft legislation will close on December 22, 2024.
December 3, 2024
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Australia: Parliament passes legislation implementing public country-by-country reporting
The legislation now awaits Royal Assent.
December 2, 2024
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Australia: Parliament passes Pillar Two minimum tax bills
The legislation now awaits Royal Assent.
December 2, 2024
Highlighted Insights
Global Transfer Pricing Review
Comprehensive information covering more than 100 countries and feedback on more than 200 questions covering local transfer pricing rules and regulations
Read more
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Germany: Annual Tax Act 2024 passed by lower house of Parliament includes Pillar Two changes, other tax developments
Recent tax developments in Germany
October 31, 2024
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UK: Pillar Two tax measures in Autumn Budget 2024
Undertaxed profits rule (UTPR) will be included in the Finance Bill 2024-2025
October 31, 2024
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EU: Proposal for exchange of Pillar Two global minimum tax information between EU member states (DAC9)
DAC9 proposal would transpose the global anti-base erosion (GloBE) information return (GIR) into EU law.
October 30, 2024
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Germany: Registering Pillar Two minimum tax group leader
Ministry of Finance has published a notification form for registering the minimum tax group leader.
October 30, 2024
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Hungary: Autumn tax package includes proposed Pillar Two amendments
Tax changes expected to come into effect in Hungary
October 29, 2024
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Malta: 2025 budget includes update on Pillar Two implementation
Highlights of Budget 2025
October 29, 2024
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New Zealand: Summary of implementation of Pillar Two GloBE rules
Rules effective for fiscal years starting on or after January 1, 2025
October 29, 2024
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Isle of Man: Update on implementation of Pillar Two global minimum tax
The new rules would take effect for accounting periods beginning on or after January 1, 2025.
October 28, 2024
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Austria: Appointment of alternative Pillar Two taxpayer due by December 31, 2024
Proof of appointment must also be uploaded in FinanzOnline
October 24, 2024
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OECD: Developments in international tax reform—digitalization of the economy and BEPS minimum standards
Recent developments in international tax reform since July 2024
October 24, 2024
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Belgium: Public consultation on draft tax return under Pillar Two rules
Comments are due November 8, 2024.
October 21, 2024
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OECD: BEPS Actions 5 and 14 peer reviews
Second round of BEPS Action 5 peer reviews, first two batches of BEPS Action 14 peer reviews under simplified review process
October 16, 2024
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Bulgaria: Public consultation on proposed amendments to Pillar Two rules
The consultation runs until October 18, 2024.
October 16, 2024
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Netherlands: 2025 Tax Plan includes proposed amendments to Pillar Two rules
Most of the proposed amendments would have retroactive effect as of December 31, 2023.
October 16, 2024
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Slovakia: Draft legislation amending Pillar Two rules submitted to Parliament
The proposed amendments would become effective as of December 31, 2024.
October 16, 2024
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Lithuania: Public consultation on draft legislation fully implementing Pillar Two rules
The proposed Pillar Two rules would closely follow the text of the EU minimum tax directive.
October 16, 2024
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Italy: Public country-by-country reporting implemented
The new provisions apply to financial years beginning on or after June 22, 2024.
October 16, 2024
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Australia: Guidance on compliance approach to restructuring transactions in response to new thin capitalization rules
The draft guidance describes a series of low-risk and high-risk factors and a four-color-coded risk-assessment framework.
October 15, 2024
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France: Finance Bill 2025 includes proposed retroactive tax increases for large corporations and individuals, updates to Pillar Two rules
The Finance Bill for 2025 was published on October 10, 2024.
October 15, 2024
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Ireland: Tax measures in Finance Bill 2024, including Pillar One Amount B rules, amendments to Pillar Two rules
Includes tax measures announced in 2025 budget
October 11, 2024
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UK: Initial analysis of OECD’s model competent authority agreement on application of Amount B under Pillar One
MCAA can be used to apply Amount B when there is a tax treaty in place between two jurisdictions
October 10, 2024
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EU: Updated list of non-cooperative tax jurisdictions
EU blacklist now consists of 11 jurisdictions
October 9, 2024
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Netherlands: Interest deduction limitation anti-profit shifting rule permissible under EU law (CJEU judgment)
Rule is justified as a means of combating tax fraud and evasion
October 8, 2024
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KPMG article: Impact of principal purpose test (PPT) provisions on holding companies in Latin America
PPT provisions make testing availability of treaty benefits for holding companies more complex
October 8, 2024
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Brazil: Implementation of Pillar Two rules establishes qualified domestic minimum top-up tax
Officially aligns Brazil with countries that have adopted the OECD's global anti-base erosion (GloBE) rules
October 7, 2024
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New Zealand: Updated compliance focus guide for multinationals reflects BEPS, Pillar Two changes
Guidance for multinationals in self-assessing their international tax and transfer pricing risk profiles
October 7, 2024
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OECD: Model competent authority agreement on application of Amount B under Pillar One
Intended to assist countries in resolving potential double taxation in connection with application of Amount B when there is a bilateral tax treaty in effect
October 7, 2024
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Poland: Draft legislation implementing Pillar Two global minimum tax rules submitted to lower house of Parliament
The legislation is expected to become effective January 1, 2025.
October 2, 2024
Tax Services
News
UK: Consultation on additional draft guidance on Pillar Two global minimum tax rules
Comments are due by October 23, 2024.
September 26, 2024
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KPMG report: U.S. transfer pricing and international tax year-end considerations
A report that includes key year-end transfer pricing and international tax issues.
September 25, 2024
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Australia: Increased reporting requirements for Local file
Proposed Local file and Master file XML schema 4.0
September 20, 2024
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OECD: Jurisdictions sign multilateral convention implementing Pillar Two subject to tax rule
Nine jurisdictions signed the multilateral convention to implement the STTR in bilateral income tax treaties.
September 19, 2024
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KPMG comments on European Commission consultation on ATAD
Evaluation of the Anti-Tax Avoidance Directive
September 19, 2024
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UK: European Commission’s finding of unlawful State aid annulled, judgment of General Court set aside (CJEU judgment)
The CJEU found that the EC and the General Court erred in law.
September 19, 2024
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Czech Republic: Proposed amendment to legislation introducing top-up tax, implementing EU directive on global minimum tax
A draft amendment to the law introducing a top-up tax to implement the EU directive on global minimum tax in the Czech Republic
August 27, 2024
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Germany: Proposed investment tax incentives, Pillar Two changes, intra-group financing transfer pricing guidance, MLI law enacted
Recent tax developments in Germany
August 27, 2024
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KPMG report: Survey on application of control of risk and DEMPE frameworks, focus on India and South Korea
How tax authorities are approaching the control of risk and development, enhancement, maintenance, protection, and exploitation (DEMPE) frameworks
August 26, 2024
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Australia: Proposed amendments to legislation implementing Pillar Two global minimum tax rules
The federal government proposed amendments to legislation implementing Pillar Two global minimum tax rules currently before parliament.
August 23, 2024
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Australia: Legislation implementing Pillar Two global minimum tax rules passes House of Representatives
The bills now move to the Senate for consideration.
August 22, 2024
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KPMG report: Potential effects on businesses of new UN tax treaty
A KPMG report that reviews the UN’s efforts to create a new tax treaty and explains why businesses need to monitor the UN process
August 21, 2024
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Poland: Domestic rules implementing DAC6 unconstitutional to extent tax advisors obliged to violate professional secrecy
A Constitutional Tribunal decision concerning domestic rules implementing DAC6 unconstitutional.
July 31, 2024
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Belgium: Mandatory disclosure rules (DAC6) compatible with EU law (CJEU judgment)
CJEU confirmed validity of mandatory automatic exchange of information for cross-border arrangements
July 31, 2024
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Australia: Updated thin capitalisation web guidance
The ATO updated its thin capitalisation web guidance to assist entities that need to apply the new thin capitalisation rules.
July 31, 2024
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Austria: Public country-by-country reporting implemented, draft amendments to transfer pricing guidelines
The law applies to financial years beginning after June 21, 2024.
July 30, 2024
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Tax report to G20 Finance Ministers and Central Bank Governors; other reports on international tax reform developments
The report describes key developments in international tax reform since February 2024.
July 25, 2024
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UN: Revised draft terms of reference for UN framework convention on international tax cooperation
A revised draft of terms of reference for a United Nations framework convention on international tax cooperation.
July 25, 2024
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Germany: Draft bill for Annual Tax Act 2024 published, includes Pillar Two changes; other tax developments
Recent tax developments in Germany
June 28, 2024
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OECD: Algeria signs MLI
Algeria signed the Multilateral Convention to Implement Tax Treaty—becoming the 103rd jurisdiction to join the MLI.
June 28, 2024
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KPMG report: Accounting for income tax implications of Pillar Two GloBE top-up taxes
A KPMG report that discusses how implementing the new rules and determining the appropriate accounting impacts may be challenging.
June 25, 2024
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Canada: Outstanding tax measures enacted, including Pillar Two, EIFEL, hybrid mismatch, clean economy, and GAAR
Tax measures previously proposed in the federal budgets of 2022, 2023, and 2024, as well as the 2023 federal economic update
June 24, 2024
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EU: EC concludes Germany’s special tax rules for public casino operators are illegal State aid
Germany must now recover the State aid, including interest, and repeal the tax rules.
June 20, 2024
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Luxembourg: Draft law amending Pillar Two law introduced to Parliament
Bill 8396 amending the Pillar Two law enacted in December 2023 was introduced to Parliament on June 12, 2024.
June 20, 2024
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OECD: Updated guidance on implementation of country-by-country reporting clarifies reporting of dividends
Updates treatment of dividends to align with the Pillar Two anti-arbitrage rules as applicable to the Transitional CbCR Safe Harbor
June 3, 2024
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Statement by co-chairs of Inclusive Framework on BEPS indicates final negotiations on Pillar One nearing completion
The OECD released a statement by the co-chairs of the Inclusive Framework on Base Erosion and Profit Shifting.
May 30, 2024
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Japan: Explanation of guidance on income inclusion rule, associated forms and schedules
National Tax Agency explanation of guidance relating to the income inclusion rule
May 30, 2024
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Belgium: Due date for first GloBE registration is July 13, 2024
July 13 is the due date for the first notification deadline for GloBE registration in Belgium
May 29, 2024
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Germany: Law implementing MLI passed by lower house of Parliament, other tax developments
The lower house of Parliament passed the "Law on the Application of the Multilateral Convention of 24 November 2016 and Further Measures."
May 28, 2024
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Crown Dependencies: Details on plans to implement Pillar Two global minimum tax
All islands have expressed intention to work cooperatively, but each is adopting a different approach.
May 24, 2024
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Slovakia: Guidelines on transfer pricing documentation for 2023
The Ministry of Finance released guidelines on the content of transfer pricing documentation for 2023.
April 30, 2024
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OECD: Consolidated commentary on Pillar Two rules, updated Pillar Two examples
The OECD released a consolidated commentary to Pillar Two global anti-base erosion (GloBE) rules.
April 30, 2024
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Poland: Draft bill implementing Pillar Two global minimum tax published
Provides for an income inclusion rule, qualified domestic minimum top-up tax, and undertaxed profit rule
April 29, 2024
News
OECD: Tax inspectors without borders 2024 annual report, new focus on country-by-country data and digital economy
Updates on international tax initiative to assist developing countries in boosting tax revenues and better mobilizing domestic resources
April 29, 2024
News
Germany: Draft bill for Annual Tax Act 2024 includes Pillar Two changes, other tax developments
Recent tax developments in Germany
April 25, 2024
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Korea: Interest deductions could be challenged on arm’s length grounds, but not wholly denied as tax avoidance
Tax Tribunal decision
April 25, 2024
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Netherlands: Public country-by-country reporting implemented
Public CbC reporting rules apply to financial years starting on or after 22 June 2024.
March 29, 2024
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Luxembourg: Guidance under Pillar Two law relating to inclusion of deferred tax assets and liabilities in computing ETR
Clarifications with respect to Article 53 of the Pillar Two law enacted in December 2023
March 28, 2024
News
Netherlands: Interest deduction denied under fraud provision of corporate income tax law (Supreme Court decision)
A Supreme Court decision concerning whether interest deduction may be denied under fraud provision of corporate income tax law
March 27, 2024
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Ireland: Tax changes for the asset management and funds industry, including Pillar Two rules
Legislative and revenue practice changes that may have an impact for funds and the asset management industry
March 25, 2024
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Australia: Consultation on draft legislation implementing Pillar Two global minimum tax rules
Consultation on primary legislation closes 16 April 2024, and consultation on subordinate legislation closes 16 May 2024.
March 22, 2024
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Finland: Legislation implementing Pillar Two global minimum tax
New legislation effective 1 January 2024 and introduces a Finnish domestic minimum top-up tax (DMTT)
March 21, 2024
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OECD: Report to G20 Finance Ministers and Central Bank Governors, updates on developments in international tax reforms
Latest developments include BEPS initiatives, tax transparency efforts and other G20 tax deliverables
February 29, 2024
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Slovakia: Legislation implementing Pillar Two global minimum tax passed by Parliament
Legislation introduces a so-called “top-up tax”
February 23, 2024
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KPMG report: Overview and initial observations on Pillar One – Amount B
Overview of the OECD report on Amount B and initial observations on how multinationals can respond
February 21, 2024
News
EU: Updates to list of non-cooperative jurisdictions
EU blacklist now consists of 12 jurisdictions
February 21, 2024
News
KPMG report: HMRC guidance on OECD’s control of risk framework
Implications that HMRC guidance has for transfer pricing policies
February 21, 2024
News
Nigeria: Migration of electronic platform for filing transfer pricing returns and country-by-country notifications
Taxpayers have until 30 June 2024 to fulfill all pending filing obligations relating to filings on TaxPro-Max.
February 20, 2024
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Sweden: European Commission opens State aid investigation into non-food biogas and bio-propane tax exemption schemes
Investigation follows the General Court's annulment of two previous EC decisions approving the tax exemptions
January 30, 2024
News
Germany: Final guidance on CFC rules, other tax developments
Final guidance on application of the Foreign Transactions Tax Act (FTTA)
January 30, 2024
News
OECD: Aggregated ICAP statistics
Key takeaways from the statistics
January 29, 2024
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Australia: Guide on hybrid mismatch rules; new case studies on offshore tax evasion
Hybrid mismatch rules largely follow the OECD hybrid mismatch and branch mismatch rules from Action 2
January 29, 2024
News
OECD: Comments on public consultation on model treaty commentary on extractible natural resources
Comments received on public consultation document on proposed changes to commentary on Article 5 of the OECD Model Tax Convention
January 22, 2024
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Italy: Procedure for obtaining hybrid mismatch penalty protection
Rules allowing taxpayers to obtain penalty protection relating to hybrid mismatch disputes by compiling certain documentary evidence
January 19, 2024
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