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The dividends, interest, and capital gains articles of the tax treaty between Austria and Belarus have been suspended until December 31, 2026.
With respect to Belarus, the suspension is effective from June 1, 2024, to December 31, 2026. With respect to Austria, the suspension is effective from June 28, 2024, to December 31, 2026. In general, the allocation of taxation rights between Austria and Belarus under the tax treaty remains unaffected, with the exception of Articles 10, 11, and 13 of the tax treaty. The Inland Revenue Authority of Singapore has published an updated version of the country’s transfer pricing guidelines.
The seventh edition of the transfer pricing guidelines, which was published on June 14, 2024, incorporates frequently asked questions (FAQs) regarding the making of working capital adjustment. The guidelines include new exemption rules for related party domestic loans entered into on or after January 1, 2025. Additionally, there is an increase in the threshold for exemption from transfer pricing documentation for certain transactions from SGD 1 million to SGD 2 million. Updated guidelines include new FAQs regarding transfer pricing documentation for long term loans and provision of information to supplement an existing transfer pricing documentation. On May 30, 2024, Ireland and Oman signed a tax treaty.
Further details will be reported when available. OECD Secretary-General Mathias Cormann has welcomed the commitment of the 147 Members of the Inclusive Framework on Base Erosion and Profit-Shifting to keep working to resolve any remaining issues in time to start the signing process of the Multilateral Convention (MLC) implementing Amount A of Pillar One by the end of June this year.
This week’s Inclusive Framework plenary meeting has clarified the outstanding issues in its ongoing effort to reach agreement on a fairer allocation of taxing rights across the globe. It has also been an opportunity to reflect on the significant progress already realized over more than a decade of multilateral discussions on addressing the tax challenges arising from digitalization and globalization of the economy. |
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November 2025
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