Check the latest developments and regulatory updates on Jannuary 2025
Argentina | Rates-National/Federal
Argentina’s tax authority (ARCA) has released revised corporate income tax brackets and rates for 2025 on 23 January 2025. Starting from fiscal years beginning on or after 1 January 2025, corporate income tax rates will be applied based on the following brackets: Up to ARS 101,679,575.26: 25%; ARS 101,679,575.26 to ARS 1,016,795,752.62: 30%; and over ARS 1,016,795,752.62: 35%
France | Tax Compliance
The French tax authorities introduced a Form n°2065-INT-SD intended for entities subject to the French Pillar Two law on 24 January 2025. The form was previously used to submit the Country-by-Country (CbC) reporting notification alongside the annual tax return. The updated version now serves both as the CbC notification and as a notification for the Pillar Two global minimum tax rules.
Russia | Rates-National/Federal
Russia has introduced several changes to its Tax Code, effective starting 1 January 2025, which includes changes to the corporate income tax rate, simplified tax regime and tourist tax. The corporate income tax (CIT) rate has been raised from 20% to 25%.
Thailand | Special tax rate
Thailand’s Revenue Department has announced the publication of the Emergency Decree on Top-up Tax B.E. 2567 (2024) in the Official Gazette on 26 December 2024,introducing the implementation of a domestic minimum top-up tax for MNE groups with a consolidated revenue of at least EUR 750 million,
Turkey | Sanctions for non-compliance
The Turkish government has announced increased tax penalties effective from 1 January 2025, based on a 43.93% revaluation rate. Under General Communiqué No. 577, first-degree irregularities incur a TRY 28,000 penalty, while second-degree irregularities cost TRY 14,000. Failing to issue required documents results in escalating fines, starting at TRY 14,000 and reaching up to TRY 140,000 for repeated offenses. The penalty for refusing to provide requested information is TRY 28,000, and the renunciation from accrual penalty is TRY 280.
United Kingdom | Special tax rate
The UK tax authority, HMRC, has opened a public consultation on the supplementary draft guidance regarding the Multinational Top-up Tax and Domestic Top-up Tax on 28 January 2025. This release of draft guidance contains sections on flow-through entities, joint ventures, the insurance sector, additional top-up amounts, and other topics. It also contains draft guidance on the undertaxed profits rule (UTPR) and certain other provisions that have been amended or introduced in the current Finance Bill. The consultation will conclude on 8 April 2025.
United States | Minor Outlying Islands (THE)
Tax Compliance California Governor Newsom announced that the California Franchise Tax Board (FTB) will provide state disaster tax relief for taxpayers and businesses affected by the recent wildfires in Los Angeles. Taxpayers will be granted a postponement to 15 October 2025 to file their returns on 2024 income and make any tax payments that would have been due 7 January 2025. The postponement includes: Quarterly estimated tax payments normally due on 15 January, 15 April, 15 June, and 15 September 2025; business entities whose corporate or pass-through entity tax returns are normally due on 15 March and 15 April 2025; pass-through entity (PTE) elective tax payments normally due on 15 March and 15 June 2025 and tax-exempt organisation returns normally due on 15 May 2025.
Germany | Documentation-Requirement
The Fourth Bureaucracy Relief Act, effective 1 January 2025, introduces significant updates to Germany’s transfer pricing documentation requirements. It was passed by parliament on 18 October 2024 and published in the Official Gazette on 29 October 2024.
Nigeria | Information exchange-Multilateral
Nigeria’s Federal Inland Revenue Service (FIRS) has released detailed guidelines on Advance Pricing Agreements (APAs), providing a framework for companies to establish transfer pricing agreements with tax authorities in advance. The guidance outlines the procedures for managing executed APAs as well as key operational procedures and compliance obligations.
Romania | CbC reporting requirement-General rule
Romania’s Ministry of Finance, in a release, outlined the preliminary format for public Country-by-Country (CbC) reporting. This follows after Romania has introduced public country-by-country (CbC) reporting requirements through Order no. 2.048 of 1 September 2022 under the Directive (EU) 2021/2101.
