Tax Treaty Brief: February 2024
France and Moldova On 25 January 2024, the French lower house of parliament approved the Double Taxation Agreement (DTA) with Moldova. Rwanda and Jordan On 25 January 2024, the Rwandan Cabinet gave its approval to the draft law for
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World Tax Brief: February 2024
Argentina Incentives: The Argentine Executive Branch proposed a bill introducing a new "Incentive Regime for Large Investments”. It aims to provide predictability and stability for investors committing to large projects, offering tax and
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Transfer Pricing Brief: February 2024
Australia Special rules for hybrid instruments or entities: The Australian Taxation Office (ATO) published guidance on the hybrid mismatch rules. The guidance explains why hybrid mismatch rules exist, how hybrid mismatch rules work and when
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Tax Treaty Brief: January 2024
Germany and Sweden On 31 December 2023, the amending protocol to the Double Taxation Agreement (DTA) between Germany and Sweden entered into force. In general, the provisions of the protocol apply from 1 January 2024. Oman and Russia On
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World Tax Brief: January 2024
Belgium International-CFC: The government proposes stricter rules on taxing undistributed income of controlled foreign companies, shifting from anti-avoidance to targeting passive income in the EU Anti-Tax Avoidance Directive. Double taxation
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Transfer Pricing Brief: January 2024
Algeria Transfer pricing information return: Algeria published the Supplementary Finance Law for 2023 in the Official Gazette. A new transfer pricing declaration obligation has been introduced, requiring taxpayers to submit an online transfer
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Tax Treaty Brief: December 2023
Belarus and Equatorial Guinea On 28 November 2023, Mr. Alexander Lukashenko, the President of Belarus signed a decree that grants approval to negotiate and sign of a Double Taxation Agreement (DTA) with Equatorial Guinea. Moldova and
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World Tax Brief: December 2023
Albania Rates-National/Federal: Albania enacted Instruction No. 26 on 19 September 2023, implementing the new Income Tax Law No. 29/2023 effective from 1 January 2024. Key changes include a standard 15% corporate income tax rate, with reduced
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Transfer Pricing Brief: December 2023
Australia Restriction on interest deduction: On 28 November 2023, the Australian government released the amendments and a supplementary explanatory memorandum to the interest limitation rules within the Treasury Laws Amendment (Making
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Tax Treaty Brief: November 2023
Croatia and Cyprus On 27 October 2023, Cyprus ratified the Double Taxation Agreement (DTA) with Croatia. Cambodia, Congo (Dem. Rep.), Senegal, Sri Lanka, and Turkey On 26 October 2023, the Turkish Parliament approved the Double Taxation
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World Tax Brief: November 2023
Argentina Payment of tax: The Argentine Federal Tax Authority (AFIP) introduced General Resolution No. 5424/2023, requiring income tax prepayment for companies in Financial Intermediation, Insurance Services, or registered as payment service
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Tax Treaty Brief: October 2023
Andorra and Croatia On 28 September 2023, the Croatian parliament approved the ratification of the Double Taxation Agreement (DTA) with Andorra. Iran and Ukraine On 26 September 2023, Ukraine has published Letter No. 72/14-612/1-114650
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World Tax Brief: October 2023
Argentina Payment of tax: On 4 September 2023, the Argentine Official Gazette published General Resolution No. 5411/2023, extending integrated tax payment deadlines for small business taxpayers. Based on Categories A, B, C and D tax payment
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Transfer Pricing Brief: October 2023
Armenia Compliance with BEPS standards: On 25 September 2023, Armenia deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent BEPS (MLI). See the story in
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Tax Treaty Brief: September 2023
Bangladesh and Hong Kong On 30 August 2023, the Govt. officials from Bangladesh and Hong Kong signed a Double Taxation Agreement (DTA) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
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World Tax Brief: September 2023
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
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Transfer Pricing Brief: September 2023
Australia Audit risk assessment: The Australian National Audit Office (ANAO) is conducting a performance audit to evaluate the efficiency of the Australian Taxation Office’s (ATO) transfer pricing (TP) management concerning loans between
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Tax Treaty Brief: August 2023
Albania and Slovak Republic On 26 July 2023, the Council of Ministers in Albania approved the draft legislation for the ratification of the Double Taxation Agreement (DTA) with the Slovak Republic. Germany and Switzerland On 26 July
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