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Week in Tax: March 17 � 21, 2025

Recent tax developments from around the globe for the week of March 17 � 21, 2025

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March 24, 2025

ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø Week in Tax—published weekly to provide an overview of tax developments as reported in TaxNewsFlash—includes summaries of select tax-related news followed by a full list of reports (more information can be found at the links provided). Highlights include:

  • Brazil: The government submitted to Congress draft legislation that would introduce a 10% withholding income tax on dividends paid to foreign investors effective as of 2026. Read TaxNewsFlash
  • Italy: A Ministerial Decree introduces a global anti-base erosion (GloBE) information return (GIR) notification requirement for groups in scope of the Italian Pillar Two legislation and includes a notification template. Read TaxNewsFlash
  • Slovenia: The Ministry of Finance unveiled a revised law project mandating electronic invoicing (e-invoicing), effective January 1, 2027. Read TaxNewsFlash
  • South Africa: The 2025/2026 budget includes proposals to introduce additional anti-avoidance measures relating to third-party backed shares, amend the definition of “hybrid-equity instrumentsâ€� to address schemes that circumvent the application of the anti-avoidance provisions in relation to preference shares, and amend the interest limitation provisions. Read TaxNewsFlash

United States

  • Announcement 2025-8: Competent authority arrangement under U.S.-Switzerland treaty regarding dividends received by retirement plans
  • ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø report: Final regulations on clean electricity production and investment credits under sections 45Y and 48E
  • ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø article: Effect of digital transformation on transfer pricing

Read TaxNewsFlash-United States

Transfer Pricing

  • Bahrain: Updated domestic minimum top-up tax (DMTT) registration manual
  • Italy: Ministerial Decree on GloBE information return (GIR) notifications
  • Turkey: Announcement that Amount B under Pillar One will not be applied
  • ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø article: Effect of digital transformation on transfer pricing

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

  • Barbados: Updated FATCA guidance on U.S. TIN reporting requirements
  • Costa Rica: Consultation on selection and risk criteria for CRS compliance audits
  • Finland: Updated FATCA and CRS FAQs
  • Switzerland: Consultation on revised FATCA agreement with United States

Read TaxNewsFlash-FATCA / IGA / CRS

Africa

  • Egypt: Amendments to tax procedures; tax incentives for small businesses
  • South Africa: Tax measures in 2025/2026 budget
  • Tanzania: Guidance regarding submission of beneficial owner information to registrar of companies
  • West Africa: Tax developments in Nigeria and Ghana in FY2024

Read TaxNewsFlash-Africa

Americas

  • Brazil: Proposed 10% withholding tax on dividends to foreign investors
  • Canada: Tax measures in 2025 budget (Manitoba)
  • Canada: Tax measures in 2025 budget (New Brunswick)
  • Canada: Tax measures in 2025 budget (Saskatchewan)
  • Colombia: Customs sanctioning scheme held unconstitutional (Constitutional Court decision)

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: Impact statement on recent Full Federal Court Division 7A decision
  • Bahrain: Updated domestic minimum top-up tax (DMTT) registration manual
  • India: Clarification to guidance that grandfathering provisions in tax treaties are excluded from principal purpose test
  • India: Rights entitlements not company shares for purposes of Ireland treaty (Tribunal decision)
  • Thailand: Carbon tax on oil approved by Cabinet
  • Thailand: Reduced corporate tax rate for special economic zones approved by Cabinet
  • Turkey: Announcement that Amount B under Pillar One will not be applied
  • Turkey: Suspended inflation adjustments for first three advance tax periods in FY2025
  • Turkey: Updated guides on taxation of business income
  • UAE: Guidance on recent amendment to VAT regulation
  • UAE: Accreditation process for e-invoicing

Read TaxNewsFlash-Asia Pacific

Europe

  • Denmark: VAT amendments relating to copyright licensing
  • Denmark: Various tax amendments enacted
  • France: Retroactive application of exit tax incompatible with EU law (Supreme Administrative Court decision)
  • Hungary: New import VAT deduction requirements include partner due diligence obligations
  • Italy: Ministerial Decree on GloBE information return (GIR) notifications
  • Netherlands: Draft legislation on “rebuttal provisionâ€� for new “Box 3â€� (wealth tax) regime presented to lower house of Parliament
  • Poland: Certain EU non-cooperative jurisdictions not included in list of countries applying harmful tax competition
  • Poland: Re-registered entity qualifies as taxpayer starting business activities for corporate income tax purposes (Supreme Administrative Court decision)
  • Serbia: Law on central register of beneficial owners enacted
  • Slovenia: Revised law project mandating e-invoicing
  • Switzerland: Consultation on proposal to introduce qualified refundable R&D tax credit (canton of Lucerne)
  • Switzerland: Implementation of cryptoasset reporting framework MCAA
  • UK: Consultation on future of oil and gas taxation

Read TaxNewsFlash-Europe

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