OECD Consulting on Ukrainian Transfer Pricing Framework—Key Global Tax Updates

Editorial Team – [2025] 174 taxmann.com 69 (Article)

1. OECD Consulting on Ukrainian Transfer Pricing framework

The OECD has announced its working with Ukraine’s Ministry of Finance to bring the country’s Transfer Pricing Framework in line with the OECD Transfer Pricing Guidelines. As part of this initiative, the Ministry has initiated a public consultation to collect feedback from multinational enterprises, individual experts, and other relevant stakeholders, ensuring that their perspectives are considered in the reform process. The deadline for submitting input has been extended to 15 May 2025.

Source – Public Consultant

2. Taiwan Issues Guidelines on Alien Individual Income Tax Return Filing

According to the Changhua Branch of the National Taxation Bureau of the Central Area, Ministry of Finance, alien individuals who have income derived from sources within the Republic of China (R.O.C.) and reside (or stay) in the R.O.C. for more than 183 days during the 2024 calendar year are required to file an alien individual income tax return.

The Branch further clarifies that foreign nationals who reside (or stay) in the R.O.C. for more than 183 days in 2024 and do not plan to leave Taiwan before April 30, 2025, must file their 2024 alien individual income tax return with the local National Taxation Bureau office based on the address listed on their Alien Resident Certificate. The filing period is from May 1 to June 30, 2025.

Applicable amounts for exemptions and deductions are as follows –

(a) Exemptions – NT$97,000 per qualifying individual (taxpayer, spouse, and dependents). For the taxpayer, spouse, or lineal ascendants aged 70 or above, the exemption is NT$145,500 per person.

(b) Standard Deduction – NT$131,000 for individual taxpayers, and NT$262,000 for joint filers with a spouse.

(c) Basic Living Expense – NT$210,000 per person.

(d) Special Deduction for Salaries or Wages – Up to NT$218,000 per person.

The Branch also reminds alien individuals who stay in Taiwan for more than 183 days in 2024 and intend to leave the country before April 30, 2025, without returning, that they must file their individual income tax return prior to departure. In such cases, the applicable exemptions, standard deduction, and basic living expense amounts will be calculated in proportion to their duration of stay in the R.O.C. during the year.

Source – Notice

3. Singapore Updates Guidance Note on Payments Subject to Withholding Tax

The Inland Revenue Authority of Singapore (IRAS) has issued revised guidance on payments that are subject to withholding tax. The updated guidance outlines the categories of payments to non-resident companies that attract withholding tax, including:

• Interest, commissions, or fees related to any loan or indebtedness;
• Royalties or other payments for the use of, or the right to use, any movable property;
• Payments for the use of, or the right to use, scientific, technical, industrial, or commercial knowledge or information, or for services or assistance connected with the application or use of such knowledge or information;
• Management fees;
• Rent or other charges for the use of movable property;
• Payments for the acquisition of real property from a non-resident property trader;
• Payments derived from structured products (excluding those qualifying for exemption under Section 13(1)(zj) of the Income Tax Act 1947); and
• Distributions made by a real estate investment trust (REIT).

The guidance also includes details on the withholding tax treatment applicable to these specific types of payments, along with a set of frequently asked questions to address common scenarios.

Source – IRAS.GOV