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[World Tax News] OECD Updates GloBE Model Rules Commentary

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OECD GloBE 2025 update

Editorial Team – [2025] 174 taxmann.com 584 (Article)

World Tax News provides a weekly snippet of tax news from around the globe. Here is a glimpse of the tax happening in the world this week –

1. OECD updates GloBE Model Rules commentary

The OECD has released the 2025 update to the Consolidated Commentary on the Global Anti-Base Erosion (GloBE) Model Rules. The updated version integrates administrative guidance issued by the Inclusive Framework between March 2022 and March 2025.

The GloBE Rules, a central element of the OECD/G20 BEPS project, ensure that large multinational enterprises pay a minimum level of tax in each jurisdiction where they operate. The Commentary clarifies the rules’ intended outcomes, defines key terms, and illustrates their application. The updated Consolidated Commentary aims to support consistent interpretation and application by tax authorities and MNE Groups worldwide.

Source – OECD

2. Australia Taxation Office unveils ‘wild’ tax deduction attempts and priorities for 2025

The Australian Taxation Office (ATO) has issued a release unveiling ‘wild’ tax deduction attempts and priorities for 2025. This includes a focus on areas the ATO frequently sees errors, including work-related expenses, working from home deductions, and in respect to multiple income sources.

Some of the most outrageous deduction attempts the ATO saw last year included:

  • A mechanic tried to claim an air fryer, microwave, 2 vacuum cleaners, a TV, gaming console and gaming accessories as work-related. The claim was denied as these expenses are personal in nature.
  • A truck driver tried to claim swimwear because it was hot where they stopped in transit and they wanted to go for a swim. The claim was denied as these expenses are personal in nature.
  • A manager in the fashion industry tried to claim well over $10,000 in luxury-branded clothing and accessories to be well presented at work, and to attend events, dinners and functions. The clothing was all conventional in nature and was not allowed.

ATO Assistant Commissioner Rob Thomson reminded taxpayers that deductions must be directly connected to income-earning activities, satisfy strict eligibility criteria, and be substantiated with proper records such as receipts. He noted that frequent errors occur in claims for work-related expenses, working from home deductions, and where individuals earn multiple sources of income.

For working from home, taxpayers can use either the fixed rate method (70 cents per hour) or the actual cost method, but must retain supporting documentation and cannot claim the same expense twice. The ATO also reiterated the need to declare all income sources, including side jobs, gig economy work, and app-based services, with deductions varying based on the nature of income and occupation.

Thomson cautioned taxpayers against assuming claims are valid without verification, as penalties and interest may apply. When in doubt, individuals should consult the ATO website or a registered tax agent.

Source – Release

3. Brazil removes UAE and Austrian Holding Company Regime from blacklists of favorable taxation and privileged tax regimes

The Brazilian Federal Revenue Service (RFB) has revised the lists of jurisdictions characterized by favorable tax regimes and those featuring privileged tax regimes (blacklists) under Normative Instruction No. 1.037/2010. This revision includes the removal of the United Arab Emirates (UAE), pursuant to Article 24-C of Law No. 9.430/1996, introduced by Law No. 15.079/2024.

According to the RFB, the UAE was removed from the list due to its advancements in fiscal transparency and its strategic investments in Brazil. The UAE submitted an investment plan that satisfied the conditions set forth under the amended legislation, justifying its exclusion from the list of jurisdictions with favorable taxation.

Additionally, the Austrian tax regime applicable to holding companies lacking substantial economic activity has also been delisted. Based on clarifications provided by the Austrian government, the RFB concluded that the regime no longer meets the criteria for classification as a privileged tax regime.

These amendments were enacted through Normative Instruction No. 2.265, dated 9 May 2025, published in the Official Gazette on 13 May 2025, and effective from the same date. The Instruction also revises the criteria for identifying jurisdictions with favorable taxation, including a reduction of the minimum tax rate from 20% to 17%, aligning it with the threshold used for transfer pricing purposes.

Source – Announcement

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The post [World Tax News] OECD Updates GloBE Model Rules Commentary appeared first on Taxmann Blog.

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