Australia Rates-Special tax rate: The Australian Taxation Office (ATO) officially initiated targeted public consultation regarding the adoption of Pillar 2 global minimum tax rules. The 15% global minimum tax and 15% domestic minimum tax will apply to large multinationals with annual global revenue of EUR750 million (approximately $1.2 billion) or more.
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Canada Mode for Filing: The Canada Revenue Agency (CRA) announced that businesses filing six or more information returns must file them electronically to avoid penalties. Recent legislation has amended mandatory electronic filing thresholds. Beginning 1 January 2024, businesses filing six or more information returns (slips and summaries) must file electronically.
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Rates-Special tax rate: Canada has issued draft legislation aimed at implementing the “Pillar Two” global minimum tax framework established by the OECD and the G-20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS). This rule is applicable for multinational enterprises (MNE groups) with consolidated revenues amounting to at least €750 million.
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Czech Republic Rates-Special tax rate: The Czech Ministry of Finance has released a statement regarding the introduction of a draft law to implement the Pillar 2 global minimum tax rule, in accordance with Council Directive (EU) 2022/2523 of 14 December 2022. Key provisions of the draft law include the incorporation of the Pillar 2 income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR) with the objective of establishing a minimum tax rate of 15% for multinational enterprise (MNE) groups.
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Finland Rates-Special tax rate: The Finnish Ministry of Finance introduced a draft law aligning with the EU Global Minimum Tax Directive, which includes income inclusion rule (IIR) and under-taxed profits rules (UTPR). This draft law introduces 15% minimum tax rate for multinational enterprise (MNE) groups that have earned annual consolidated revenues of at least EUR 750 million in at least two of the preceding four fiscal years.
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Germany Rates-Special tax rate: On 16 August 2023, the German Federal Cabinet approved the draft law of global minimum tax, aligning with the EU Minimum Tax Directive. The 15% minimum tax will apply to large multinationals with annual global revenue of EUR750 million (approximately $1.2 billion) or more.
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Ireland Tax Compliance: The Irish Revenue has issued eBrief No. 185/23 on research and development (R&D) corporation tax credit. Accordingly, Revenue released a new Tax and Duty Manual (TDM) Part 29-02-03A. This manual provides information about how to submit a claim for the R&D tax credit or the R&D corporation tax credit.
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Rates-Special tax rate: The Minister for the Environment, Climate and Communications has signed an order to commence the Energy (Windfall Gains in the Energy Sector) (Temporary Solidarity Contribution) Act 2023. The order is effective from 2 August 2023. This Act provides for the implementation of the temporary solidarity contribution outlined in Council Regulation (EU) 2022/1854 of 6 October 2022.
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Luxembourg Rates-Special tax rate: Government presented a draft law (Bill 8292) to the Parliament aligning with the OECD’s Pillar Two global minimum tax rules and EU Minimum Tax Directive of 15% minimum tax for large multinational groups with global consolidated revenue at least €750 million.
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Russia Treatment of losses: Russia has published Federal Law No. 389-FZ on 31 July 2023, making amendments to the Russian Tax Code. It extends the limit on offsetting carried forward losses to 50% of taxable income annually until 31 December 2026 (previously 31 December 2024).
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Rates-Special tax rate: Russia will introduce a 10% one-time windfall tax starting from 1 January 2024. This tax applies to excess profits for FY 2021-2022 for Russian companies, foreign companies with Russian tax residency, and foreign companies with permanent establishments in Russia. Early payment at a reduced 5% rate is applicable between October 1 and 30 November 2023, with a deadline of 28 January 2024 for tax payment.
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Slovak Republic Rates-Special tax rate: The Slovak Republic Ministry of Finance has initiated a public consultation process to get feedback on a draft law aimed at implementing global minimum corporate tax rule. The 15% proposed minimum tax rate will be applicable to companies with annual consolidated revenues of at least EUR 750 million in at least two of the previous four accounting periods.
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Korea, Rep Of Rates-Special tax rate: South Korea enacted 15% global minimum tax rules in December 2022. The global minimum tax rules are in line with the OECD Pillar Two Model Rules and encompass the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR). As per the presently enacted tax legislation, both rules are set to take effect for fiscal years commencing on or after 1 January 2024.
International-Transfer Pricing Rules: The tax reform proposal reduces the deadline for submitting the Local file and Master file to six months, and additionally, large companies submitting a Local file would also be obliged to submit the Statement of International Transaction. The changes will be effective from 1 January 2024.
Incentives-Small business: Small and medium-sized enterprises are eligible for a 50% tax reduction on income generated from technology transfer and a 25% tax reduction on income from technology licensing. This benefit will be extended from 31 December 2023 to 31 December 2026.
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Taiwan Sanctions for non-compliance: The Taichung Branch of the National Taxation Bureau outlines the consequences of failing to file annual income tax returns on time. If a business fails to file within the specified period, they will receive a notice to do so within 15 days. If they still don’t file, the tax authority shall make provisional assessment of the amount of income and tax payable on the basis of available taxation data or the profit standard of the same trade. Furthermore, the tax authority shall levy a delinquency reporting surcharge.
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United Arab Emirates Sanctions for non-compliance: The UAE Ministry of Finance announced the issuance of Cabinet Decision No. (75) of 2023 regarding administrative penalties for violations related to the Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses. The Cabinet Decision specifies the administrative penalties that will be imposed by the Federal Tax Authority for violations related to the application of the Corporate Tax Law, effective as of 1 August 2023.
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