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Exchange of Information & Disclosure Transparency

January 1, 2025
Exchange of Information & Disclosure Transparency

Exchange of Information & Disclosure Transparency

Mexico participates in the OECD Inclusive Framework and CbC reporting exchange agreements. The SAT exchanges and receives information on MNE groups for risk assessment and audit targeting.

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ATO Tightens Scrutiny of Related-Party Financing

The Australian Taxation Office (ATO) is introducing a new risk assessment system for loans between related international parties. Under the latest practical compliance guideline (PCG 2025/D2), companies must review transfer pricing arrangements before considering thin capitalisation, thereby increasing compliance demands for all inbound financing.

ATO Intensifies Reporting and Analytics
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ATO Intensifies Reporting and Analytics

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Major Changes to Thin Capitalisation Rules
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New Local File V4.0 Reporting Standards
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Public Country-by-Country Reporting Goes Live
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Alignment with Latest OECD TP Guidelines
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15% Global Minimum Tax Now in Effect
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15% Global Minimum Tax Now in Effect

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Landmark Alcoa Transfer Pricing Ruling
NewsJanuary 1, 2025

Landmark Alcoa Transfer Pricing Ruling

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