US: IRS clarifies CFC not eligible for dividends received deduction under section 245A
The US Internal Revenue Service (IRS) issued an Office of Chief Counsel memorandum clarifying that a controlled foreign corporation (CFC) is not eligible for a dividends received deduction under section 245A. This memorandum provides
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Taiwan issues new tax calculation guidelines for foreign companies
Taiwan's Ministry of Finance has released notice for foreign companies on applying the net profit ratio and domestic profit contribution ratio to calculate taxable income and withholding tax before receiving payments for services or business profits
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Turkey: Parliament approves law modifying tax procedure’s inflation adjustment rules
Turkey Parliament has enacted Law No. 7529, introducing amendments to the inflation adjustment provisions of the Tax Procedure Law (TPL) on 24 October 2024. The main part of Law No. 7529 involves several key updates to consumer protection,
See MoreUS: IRS updates guidance on foreign-derived intangible income deduction
The US Internal Revenue Service (IRS) issued an updated practice unit titled, ‘IRC Section 250 Deduction: Foreign-Derived Intangible Income (FDII) on 24 October 2024. This revision eliminates references to unavailable resources and replaces the
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Bangladesh considers phasing out non-refundable minimum tax
The National Board of Revenue (NBR) in Bangladesh is planning to phase out its non-refundable minimum tax system according to local sources, a move aimed at aligning with global tax standards and encouraging investor confidence. The NBR plans to
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Mexico updates list of taxpayers linked to suspected fake transactions
Mexico’s Tax Administration (Servicio de Administración Tributaria, SAT) has revised the final lists of taxpayers suspected of engaging in non-existent transactions under Article 69-B of the Federal Fiscal Code. The tax administration
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New Zealand consults use of cost method for calculating foreign investment fund income
New Zealand Inland Revenue has initiated a public consultation the draft interpretation statement, PUB00458 Income Tax – Using the Cost Method to Determine Foreign Investment Fund (FIF) Income, explaining when a resident investor can choose to
See MoreMexico introduces new withhold income tax, VAT obligations for crowdfunding platformsÂ
The Mexican tax administration (SAT) released the  Second Resolution of Modifications to the Miscellaneous Fiscal Resolution for 2024 on 11 October 2024, which mandates that crowdfunding platforms provide specific information to the SAT concerning
See MoreUS: Treasury, IRS relieves tax-exempt organisations from CAMT form filing for 2023 tax year
The US Department of Treasury and the Internal Revenue Service (IRS), in a release – IR-2024-277, granted a filing exception for tax-exempt organisations on 23 October 2024; they do not have to file Form 4626, Alternative Minimum Tax –
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US publishes updated Congressional Research Service report on SALT deduction
The US Congressional Research Service has released an updated report on the Federal Deductibility of State and Local Taxes on 16 October 2024. Under current law, taxpayers who itemise can deduct state and local real estate taxes, personal
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Ireland updates Tax and Duty Manual concerning Relief for Investments in Corporate Trades
Irish Revenue has issued eBrief No. 258/24 on 18 October 2024, updating the Tax and Duty Manual Part 16-00-02 concerning Relief for Investments in Corporate Trades. The manual has been updated to reflect changes to the Employment Investment
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OECD publishes tax arbitrage through closely held businesses report
The Organisation for Economic Co-operation and Development (OECD) issued a report on Tax arbitrage through closely held businesses on 7 October 2024. The report explores tax arbitrage incentives and behaviours in OECD countries, and their
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Colombia clarifies Significant Economic Presence rules under corporate income tax regulations
The Colombian tax authority (DIAN) has released new guidance on how companies should interpret the concept of Significant Economic Presence (SEP) under the country’s corporate income tax rules. In Ruling 713, issued on 28 August 2024, DIAN
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US: IRS rules section 246(b) tax limit applies to GILTI, FDII income
The US Internal Revenue Service (IRS) Office of Chief Counsel (OCC) has released a memorandum (AM 2024-002) that examines how the taxable income limitation under the Internal Revenue Code (IRC) section 246(b) applies to both IRC section 951A global
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Saudi Arabia introduces new real estate transaction tax regulations
Saudi Arabia has released updated regulations for its real estate transaction tax (RETT) system, published in the Official Gazette on 11 October 2024. The new rules implement a 5% tax on all real estate disposals, applying to properties without
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Taiwan publishes guidance on deductible interest rates for low or no interest loan
Taiwan’s National Taxation Bureau of the Northern Area (NTBNA), under the Ministry of Finance,stated that, if a company borrows money to pay interest on the one hand, but does not charge interest on the loan money on the other hand, or the
See MoreTurkey clarifies application of new anti-avoidance rule
The Turkish Revenue Administration has issued Income Tax General Communiqué No. 326 in the Official Gazette, outlining application measure of Law No. 7524. The purpose of this communiqué is to introduce a general anti-avoidance rule, which
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France sets new interest rates for shareholder interest deductibility
France has published interest rates for entities whose financial year (FY) ended between 30 September and 30 December 2024, which are used to determine the deductibility of interest payments to shareholders. The applicable rates from 30 September
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