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
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Mexico introduces new withhold income tax, VAT obligations for crowdfunding platforms
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
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US: 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
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Turkey 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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Malaysia consults on tax treatment of local ships
The Inland Revenue Board of Malaysia (IRBM) initiated a public consultation on a draft ruling regarding the tax treatment of Malaysian ships and the exemption of shipping income for qualifying residents. The consultation is open for comments from
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Poland approves cash accounting scheme for eligible entrepreneurs
Poland’s parliament approved a new "Cash PIT" regime aimed at individual entrepreneurs who operate their businesses independently and whose revenue did not surpass the PLN 1 million (EUR 250,000) threshold in the previous tax year. The scheme
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Australia issues law companion ruling on corporate collective investment vehicle regime
The Australian Taxation Office (ATO) released the Law Companion Ruling (LCR) 2024/1 - The Corporate Collective Investment Vehicle Regime on 2 October 2024. Effective from 1 July 2022, this Ruling is about amendments made to the taxation law to
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New Zealand issues draft guidance on loss carry forward rules
The New Zealand Inland Revenue has issued draft guidance interpreting the loss carry forward rules established in 2020, known as the business continuity test (BCT). This new draft aims to clarify anti-avoidance provisions not addressed in the
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US: IRS publishes list of entities, branches with qualified intermediary status
The US Internal Revenue Service (IRS) published its list of entities and branches that have achieved qualified intermediary (QI) status under the Foreign Account Tax Compliance Act (FATCA). The Qualified Intermediary (QI) Program administers
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Uruguay extends CIT and Net Wealth Tax exemptions, updates definition of Shared Services Centre
The Ministry of Economy and Finance in Uruguay updated the definition of “Shared Services Centre” and extended tax exemptions for Corporate Income Tax (CIT) and Net Wealth Tax, through the publishing of Decree No. 257/024 in the Official
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