December 18, 2023



BEPS and Global Tax Reforms:

Countries are implementing measures to combat profit shifting by multinationals.

  • Bulgaria: Adoption of the Pillar 2 Global Minimum Tax, aligning with OECD guidelines and showcasing a global trend towards uniform corporate taxation practices.
  • Finland: Updated synthesized text of tax treaties with Bosnia and Herzegovina, reflecting the impact of BEPS MLI, indicating an evolving international tax landscape.

Tax Treaty Developments:

  • Philippines & Brunei: Ratification of their first income tax treaty signifies a strengthening of economic ties and cross-border investment facilitation.
  • Turkey & Congo (DRC): New tax treaty ratified, highlighting ongoing efforts to enhance international tax cooperation and prevent tax evasion.
  • France: Moves to approve pending tax treaties with Denmark and Greece, reflecting a commitment to updating and expanding its tax treaty network.

Cybersecurity in Tax Administration:

  • Ukraine: Reports of a cyberattack on Russia’s Federal Tax Service, emphasizing the crucial role of cybersecurity in protecting tax administration systems.

Transfer Pricing and Corporate Tax Compliance:

  • Russia: Significant reforms in transfer pricing rules from 2024, illustrating a global shift towards more stringent tax compliance and transparency.
  • European Union & Luxembourg: CJEU upholding the General Court’s judgment on Amazon’s State Aid case, influencing future transfer pricing disputes.

Domestic Tax Policy Updates:

  • Costa Rica: Setting of corporate and individual income tax brackets and rates for 2024, indicating adaptive tax policy measures to changing economic conditions.


This week’s developments highlight a global trend towards tax harmonization and fair taxation, underscoring the importance of international cooperation in tax matters. The cybersecurity incident between Ukraine and Russia raises significant concerns about the vulnerability of national tax systems to cyber attacks. The EU’s ruling on Amazon’s case may set a new standard for corporate taxation within the bloc. These events collectively signal a dynamic shift in the global tax landscape, emphasizing the need for robust and adaptable tax policies.