Wednesday, December 10​

• Australia: Weekly tax round-up (Deloitte) More

• Canada: Canada announces new trade measures for steel imports (EY) More

• Canada: Offshore Tax Havens: an intriguing problem for Canadian tax law (Jinyan Li and Angelo Nikolakakis) More

• Costa Rica: MoF announces 2026 corporate tax rates (Regfollower) More

• Czech Republic: Changes in R&D allowances effective January 1, 2026 (KPMG) More

• Czech Republic: Comments on case concerning transfer pricing treatment of business restructuring (David Zářecký on LinkedIn) More

• Czech Republic: Documentation requirements for tax-deductible depreciation of real estate improvements (Supreme Administrative Court decision) (KPMG) More

• Germany: German cash pool participants in the focus of legislators and tax authorities (KPMG) More

• Germany: Obligation to disclose emails in tax audits (court decision) (KPMG) More

• Honduras: Honduras publishes “Guide on Country-by-Country Reporting (CbCR) Frequently Asked Questions” (EY) More

• India: Physical presence required for service PE under India-Singapore treaty (Clifford Chance case: court decision) (KPMG) More

• Malaysia: Updated guidelines on e-invoicing (Tax authorities) More

• Nigeria: Tax Appeal Tribunal affirms authority to grant interim and interlocutory reliefs in tax disputes (KPMG) More

• Poland: Parliament adopts 2026 Budget Act, increases bank tax rates (Regfollower) More

• Singapore: IRAS expands GloBE guidance with comprehensive new e-learning modules (Regfollower) More

• Spain: Spanish Supreme Court opens door for non-residents to apply the joint personal income tax-wealth tax limit – Major refund opportunity (Baker McKenzie) More

• UAE: MoF issues new resolution outlining fines for electronic invoicing non-compliance (Regfollower) More

• UAE: MoF publishes domestic minimum top-up tax guidance, FAQs (Regfollower) More

• Uganda: Comments on Translink case: fees for technical or consultancy services vs. independent personal services in Uganda / UK double tax treaty (Lucas de Lima Carvalho on LinkedIn) More

• US: District court upholds economic substance of intercompany transactions in Perrigo (Baker McKenzie) More

 

 

Tuesday, December 9

• Global: Global e–invoicing developments tracker (3 December 2025) (EY) More

• Global: Global tax talk – tax in 60 seconds (Will Morris on LinkedIn) More

• Global: More jurisdictions commit to automatic exchange of information, new reports released (Deloitte) More

• Global: OECD under growing pressure on Pillar Two (PwC video, 7:33) More

• Global: Tax trends and developments for MNEs in 2026 (Loyens & Loeff) More

• Argentina: Argentina allows exporters to convert and display tax credit balances and export refunds in US dollars (EY) More

• Australia: ATO administrative approach to public country-by-country reporting exemptions (KPMG) More

• Australia: ATO Top 500 findings report: Years of "justified trust" methodology, private groups (Deloitte) More

• Australia: Pre-capital gains tax status can be retained when shares are held through discretionary trust (Administrative Review Tribunal decision) (KPMG) More

• Belgium: Belgium announces e-invoicing tolerance period and new draft law on B2B e-invoicing mandate (EY) More

• Bosnia and Herzegovina: Updated withholding tax obligations and forms (KPMG) More

• Cameroon: Significant economic presence standard introduced from 2026 (KPMG) More

• Estonia: Significant tax changes in Estonia from 2026 (EY) More

• EU: Transfer pricing implications of CJEU judgment on application of VAT to cross-border intra-group services (KPMG) More

• France: Judgment of the Paris Administrative Court on MAP access (Rhys Bane on LinkedIn) More

• Malaysia: Stamp assessment and payment system replaced by e-Duti Setem starting January 1, 2026 (KPMG) More

• Slovakia: Slovakia revises financial transaction tax law, exempts self-employed individuals (Regfollower) More

• Taiwan: CFC current year taxable profits – deductibility of pre-CFC losses (Government) More

• Taiwan: Southern National Taxation Bureau outlines tax treaty relief for overseas e-commerce operators (Regfollower) More

• UAE: New Federal Decree-Laws amending the VAT Law and Tax Procedures Law (Baker McKenzie) More

• UK: Finance (No. 2) Bill (Government) More

• UK: Parliament considers Finance Bill containing 2025 budget proposals More

• Uruguay: Parliament modifies budget bill to clarify entry into force of the Qualified Minimum Domestic Top-Up Tax (EY) More

• US: Enhanced health care tax credit set to expire on 31 December 2025 (Deloitte) More

• US: IRS clarifies Trump accounts and international rules under OBBBA (Deloitte) More

• US: House taxwriting committee leader urges swift action on G7, Pillar Two plan (Deloitte) More

• Uzbekistan: Uzbekistan outlines 2026–28 budget and fiscal plan, proposes higher corporate income tax (Regfollower) More

• Vietnam: Circular 99: What Vietnam’s new accounting regime means for IFRS alignment (Dezan Shira and Associates) More

 

 

Monday, December 8

• Global: 2025 update to OECD model treaty (OECD) More

• Global: OECD's Global Forum 2025 Annual Report (OECD) More

• Australia: Sample #1 of GloBE rules return form (Tax authorities) More

• Australia: Sample #2 of GloBE rules return form (Tax authorities) More

• EU: Exemption of inbound dividends from non-corporate taxes under the Parent-Subsidiary Directive – Opinion Statement on decision of CJEU in Cases C-92/24 to C-94/24, Banca Mediolanum (CFE Tax Advisers Europe) More

• France: Second guidance on GloBE rules (in French) (Tax authorities) More

• Greece: Legislation allowing 200% deduction for investments in defence and related manufacturing units (in Greek) (Government) More

• Hungary: Proposed amendments to transfer pricing documentation requirements (in Hungarian) (Government) More

• India: Netflix case (Transfer pricing – limited risk distributor or entrepreneur?) (Tribunal decision) More

• Ireland: Updated guidance on hybrid mismatch rules for partnerships (Tax authorities) More

• Netherlands: Decree on tax treatment of funds for joint account (FGR) and “transparent funds” (in Dutch) (Government) More

• Sweden: Legislation amending interest deduction limitation rules (in Swedish) (Government) More

• UK: Policy paper on proposed changes to transfer pricing, permanent establishment, and Diverted Profits Tax rules (Government) More

• UK and US: US agrees to remove tariffs on UK-origin pharmaceuticals, pharmaceutical ingredients, and medical technology (Government) More

• US: Notice 2025-75: section 70354(c)(2) of OBBBA (Tax authorities) More

• US: Notice 2025-77: section 70312 of OBBBA (Tax authorities) More

• US: Notice 2025-78: section 70322 OBBBA (Tax authorities) More

 

 

Saturday, December 6

• Global: AI is already here (CIAT) More

• Global: OECD 2025 Update to the OECD Model Tax Convention — key highlights (EY) More

• Global: Pillar Two Side-by-Side challenges of EU law, global tax governance, sovereignty. Comments for a rational win-win path forward (William Byrnes and Pramod Kumar Siva) More

• Australia: ATO releases sample forms for global and domestic minimum tax filings (Regfollower) More

• Australia: Beneficial ownership, instant asset write-off bill receives Royal Assent (KPMG) More

• Belgium: Draft law confirms e-invoicing grace period and clarifies the scope of mandate for non-residents (KPMG) More

• China: China monthly tax brief: November 2025 (Dezan Shira and Associates) More

• Estonia and EU: Estonia: Implementation of the minimum tax must be flexible and thoroughly assessed – includes Estonia’s letter to the European Commission (Government) More

• Estonia and EU: Finance Minister urges EU flexibility on minimum tax (Regfollower) More

• France: Tax authorities issue second guidance on Pillar 2 global minimum tax (Regfollower) More

• Italy: Revenue Agency updated VAT exemption for SMEs across EU borders (Regfollower) More

• Kenya: High Court determines that digital platforms are liable for VAT on full customer charges (EY) More

• Korea: National Assembly approves corporate tax hike in new budget plan (Regfollower) More

• Latin America: Latin American tax news - November 2025 (Joaquin Kersman on LinkedIn) More

• Montenegro: Draft domestic minimum top-up tax published (in Croatian) (Government) More

• Slovakia: Amendment to Financial Transaction Tax Act introduces new rules (KPMG) More

• UAE: Ministry of Finance publishes Cabinet Decision on penalties for noncompliance with e-invoicing (EY) More

• UK: Finance Bill reforms to transfer pricing, permanent establishments, DPT legislation (Deloitte) More

• UK: HMRC has just updated its guidance on searching for comparables and arm’s length range (Borys Ulanenko on LinkedIn) More

• UK: New HMRC reward scheme for whistleblowers introduced (Macfarlanes) More

• UK: Primary legislation to charge NICs on salary-sacrificed pensions contributions issued (Deloitte) More

• US: Digital Advertising Services Taxes: States catch up and look ahead (Deloitte) More

• US: FTC disallowance guidance under section 960(d)(4) related to section 951A PTEP (Deloitte) More

• US: Guidance on allocation of foreign income taxes and section 987 transition rules (Notice 2025-72) (KPMG) More

• US: Report on recent US international tax developments - 5 December 2025 (EY) More

• US: State tax matters (Deloitte) More

 

 

Friday, December 5

• Global: How countries stack up in OECD’s 2024 APA Statistics Report (KPMG) More

• Global: Seven essential actions to strengthen your global Pillar Two readiness (EY) More

• Australia: Australia publishes Pillar Two compliance and administrative guidance - first returns due by 30 June 2026 (EY) More

• Australia: Sample combined Pillar Two return forms (KPMG) More

• Belgium: Grace period for mandatory B2B invoicing announced for certain businesses (Deloitte) More

• Belgium: Three-month grace period for mandatory B2B e-invoicing (Loyens & Loeff) More

• Bulgaria: Government withdraws 2026 draft budget law amid protests (Regfollower) More

• Canada, Mexico, and US: USTR request for comments on United States-Mexico-Canada Agreement (USMCA) automotive goods trade (KPMG) More

• Chile: SII implements new compliance requirements for digital platform operators, payment service providers (Regfollower) More

• EU: Triangulation simplification applies beyond three parties in EU VAT supply chains (European General Court decision) (KPMG) More

• Germany and US: German tax authorities update view on reduced WHT rates under Germany / US tax treaty (Deloitte) More

• Hungary: Proposed changes to transfer pricing documentation and data disclosure (KPMG) More

• Lithuania: Amendments to corporate income tax, VAT, excise taxes, and real estate tax, introduction of insurance premium tax (KPMG) More

• Netherlands: Updated Dutch Fund Decree: Key updates for limited partnerships and investment funds (Norton Rose Fulbright) More

• Nigeria: Guidance on withholding tax on interest from short-term securities; duty-free threshold for low-value imports; tax administration reform (KPMG) More

• US: Companies using PPI indexes to compute inflation for LIFO inventory should consider taking action before year-end (PwC) More

• US: Notices 2025-75, 2025-77, and 2025-78: Intent to issue proposed regulations regarding various international tax provisions of OBBBA (KPMG) More

• US: Treasury releases three international tax notices related to tax act enactment (PwC) More

 

 

Thursday, December 4

• Global: 5 layers of a transfer pricing audit (Borys Ulanenko on LinkedIn) More

• Global: Telecommuting and taxes (Alex Parker) More

• Global: Trade talking points (EY) More

• Argentina: Solidarity contribution: Income tax deductibility and repetition claim explained (Baker McKenzie) More

• Belgium: Three-month tolerance period for e-invoicing mandate effective January 1, 2026 (KPMG) More

• Bulgaria: Government announces withdrawal of Budget laws 2026 from parliament (in Bulgarian) (Government) More

• Canada: Beneficial ownership – legal substance – Husky Energy files application for leave to appeal to Supreme Court (Kevin Kelly on LinkedIn) More

• Chile: Tax compliance confirmation process for platforms and payment service providers (KPMG) More

• EU: E-News from KPMG’s EU Tax Centre (KPMG) More

• EU: Estonia proposes that the EU consider 3 options for the EU’s GloBE Directive (Jason Hoerner on LinkedIn) More

• EU: Proportionality stricto sensu and the need for an autonomous EU rule-of-law review in direct taxation (Dennis Weber) More

• Hungary: Hungary consults on overhaul of transfer pricing documentation rules (Regfollower) More

• India and Qatar: Income tax treaty between India and Qatar enters into force (KPMG) More

• Ireland: Irish Revenue updates guidance on anti-hybrid rules for partnerships (Regfollower) More

• Italy: De Grisogono case #1 – transfer pricing – CUP vs. TNMM (Supreme Court) (in Italian) (TPcases) More

• Italy: De Grisogono case #2 – transfer pricing – limited risk distributor – application of TNMM (Supreme Court) (in Italian) (TPcases) More

• Korea and US: US tariff modifications on products from Korea (KPMG) More

• Malawi: MoF presents 2025-26 mid-year budget review, to introduce Minimum Alternate Tax (Regfollower) More

• Netherlands: Updated Fund Decree – latest on Dutch tax classification as FGR for Dutch and non-Dutch limited partnerships (Loyens & Loeff) More

• Poland: Legislation passed by upper house of Parliament includes direct and indirect tax changes (including simplifying tax regulations on accelerated depreciation) (KPMG) More

• Poland: Summaries of recent Supreme Administrative Court decisions: (1) management fees not eligible for tax exemption; and (2) residential building not subject to property tax rate for premises used for business purposes (KPMG) More

• Portugal: CJEU rules Portuguese withholding tax partially incompatible with EU law (Deloitte) More

• Russia: Russia simplifies tax registration for foreign companies (Regfollower) More

• Singapore: Singapore’s Amount B initiative (David Zářecký on LinkedIn) More

• Turkey: Revenue Administration extends Domestic Minimum Top-Up Tax returns (Regfollower) More

• UK: Government announces mandatory e-invoicing will go live with effect from April 2029 (EY) More

• UK: Pillar Two – UK realities (PwC podcast, 30:28) More

• US: 2025 State R&D credit changes (KPMG) More

• US: Navigating the shift: The AI edge in indirect SALT—accuracy, speed, strategic insight (PwC) More

• US: Notice 2025-72 provides guidance on allocating foreign taxes (Deloitte) More

 

 

Wednesday, December 3

• Global: 2025 transfer pricing year in review (KPMG) More

• Global: Global e–invoicing developments tracker (26 November 2025) (EY) More

• Global: International tax news (November 2025) (PwC) More

• Global: Most transfer pricing local files are built the wrong way around (Borys Ulanenko) More

• Global: Peer review of the Automatic Exchange of Financial Account Information 2025 update (OECD) More

• Global: Public consultation on tax issues relevant to global mobility of individuals (KPMG) More

• Global: The New Tax Order: Evolving tax policy is rewriting the rules of business success (PwC) More

• Argentina: Argentina proposes amendments to its transfer pricing regime (EY) More

• Argentina: Recent indirect tax developments (KPMG) More

• Canada: 2025 budget implementation bill no. 1 introduced in House of Commons (EY) More

• China: Unlocking China’s new VAT law: Key changes, business impacts, and compliance tips (Dezan Shira and Associates) More

• EU: CJEU judgment on compatibility with EU law of evidentiary requirements for non-resident pension funds seeking withholding tax exemption (KPMG) More

• EU: CJEU rejects appeal from General Court decision that Madeira Free Zone scheme not implemented in line with approved conditions (KPMG) More

• EU: EU revises Generalised Scheme of Preferences (GSP) (KPMG) More

• Greece: Super-deduction regime to support investment in defence-related and allied manufacturing units (KPMG) More

• Indonesia: Tax incentives for employees in labor-intensive industries, domestic holiday flights (Deloitte) More

• Kenya: High Court rules that government's objection decision sent to wrong email was ineffective (EY) More

• Latvia: Partial implementation of reporting obligations for cryptoasset service providers (DAC8) (KPMG) More

• Philippines: Statement on the immediate and temporary suspension of all Bureau of Internal Revenue field audits and related operations (Government) More

• Sweden: Parliament approves amendments to interest deduction limitation rules (KPMG) More

• Turkey: Government extends Qualified Domestic Minimum Top-Up Tax filing and payment deadlines and releases QDMTT return format for testing (EY) More

• UK: UK introduces Budget 2025 (EY) More

• UK and US: US and UK strike agreement for tariff-free pharmaceuticals (Regfollower) More

• US: Treasury redeems complex proposed excise tax regulations (Alvarez & Marsal) More

 

 

Tuesday, December 2

• Global: GloBE rules require MNEs to remove the effects of “pushdown” purchase price accounting (PPA) adjustments from their numbers (Leonard Wagenaar on LinkedIn) More

• Global: Most transfer pricing teams still live in step 5 of this picture: documentation (Borys Ulanenko on LinkedIn) More

• Global: OECD Tax Certainty Day 2025 - consolidated information on mutual agreement procedures 2025 (Rhys Bane on LinkedIn) More

• Global: OECD’s 2025 Model Tax Convention update: What it means for multinationals (DLA Piper) More​

• Australia: Beneficial ownership, instant asset write-off bill passes parliament (KPMG) More

• Australia: Practical compliance guideline: Global and domestic minimum tax lodgment obligations - transitional approach (Tax authorities) More

• Brazil: Law 15,270/2025 enacted to tax dividends and amend personal income tax rules (Baker McKenzie) More

• Cyprus and US: Cyprus tax authorities issue clarification note regarding bilateral agreement with United States (EY) More

• Hong Kong: Management fees paid to BVI affiliate not deductible (Court of Appeal decision) (KPMG) More

• Hungary: Autumn tax package adopted, including changes to global minimum tax rules (KPMG) More

• India: Taxpayer allowed foreign tax credits on income not taxable under Japan treaty (tribunal decision) (KPMG) More

• Italy: Italy's permanent establishment concept affected by OECD 2025 Model Tax Convention update (EY) More

• Netherlands: 2026 Tax Plan adopted by lower house of Parliament, including Pillar Two changes and implementation of DAC9 (KPMG) More

• Oman: Draft data dictionary for e-invoicing (KPMG) More

• Sri Lanka: Proposed amendments to tax incentives and exemptions (Colombo Port City) (KPMG) More

• Switzerland: Swiss voters reject federal inheritance tax initiative (Baker McKenzie) More

• Switzerland: Voters reject 50% inheritance and gift tax proposal (Deloitte) More

• US: Dispute prevention and resolution options: prefiling update (KPMG) More

• US: Transfer pricing landscape shifts amid IRS changes and tariffs (Grant Thornton) More

• US: Understanding the 2025 Perrigo decision through the lens of a craps game (William Byrnes) More

• Vietnam: Vietnam VAT rates and applicability in 2025: a brief guide (Dezan Shira and Associates) More

• Zimbabwe: Direct and indirect tax proposals in 2026 budget (KPMG) More

• Zimbabwe: Government announces 2026 budget, proposes digital services withholding tax (Regfollower) More

​

 

Monday, December 1

• Global: Consultation document on global mobility of individuals (OECD) More

• Global: Corporate Tax Statistics: report and related documents (OECD) More

• Global: Report on ways to simplify taxation of cross-border business activities (OECD) More

• Australia: Announcement on reportable tax position schedule (Tax authorities) More

• Australia: Consultation paper on proposed News Bargaining incentive (Government) More

• Cambodia: Announcement on capital gains tax (in Khmer) (Government) More

• EU: Press release on evaluation of DAC (European Commission) More

• EU: Report on evaluation of DAC (European Commission) More

• EU: Working paper on VAT treatment of free-of-charge access to platform in exchange for user data (European Commission) More

• India: Notification for transfer pricing tolerance range (Tax authorities) More

• Ireland: Guidance on application of VAT grouping rules (Tax authorities) More

• Japan: Guidance on consumption tax relating to satellite launch transportation services (in Japanese) (Tax authorities) More

• New Zealand: Uber test case on whether Uber drivers are employees or independent contractors (Court decision) More

• Portugal: Guidance on new VAT group regime (in Portuguese) (Tax authorities) More

• UK: HMRC urges large businesses to review management expenses (Chartered Institute of Taxation) More

• US: Final regulations on excise tax on stock repurchases (Government) More

• US: Notice 2025-72 on repeal of one-month deferral election under section 898(c)(2) (Tax authorities) More

 

 

Saturday, November 29

• Global: Good vs. bad transfer pricing (Borys Ulanenko on LinkedIn) More

• Global: Treatment of equity accounted affiliates in GloBE rules (Chester Wee on LinkedIn) More

• Australia: ATO issues guidance on Pillar 2 filing obligations (Regfollower) More

• Australia: Monthly tax update (December 2025) (PwC) More

• EU: Commission publishes second evaluation of administrative cooperation directive (Deloitte) More

• Hong Kong: Employee fringe benefits: Tax treatment and reporting obligations (Deloitte) More

• Netherlands: Dutch tax classification of (non-)Dutch limited partnerships – current state of play (Loyens & Loeff) More

• Taiwan: Draft amendments to investment tax credit regulations announced (Deloitte) More

• Taiwan: Tax Bureau clarifies CFC investment income deductions (Regfollower) More

• UK: Autumn Budget 2025: business tax perspective (Macfarlanes) More

• UK: Government releases 2025 budget, mandates VAT e-invoicing from 2029 (Regfollower) More

• UK: UK retains SME transfer pricing exemption, plans new multinational reporting regime (Regfollower) More

• Vietnam: Summary of recent key tax legislative developments, November 2025 (Deloitte) More​​​​​​