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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India scraps tax cases due to higher appeals thresholds
India's Press Information Bureau released a statement from the Ministry of Finance regarding the Supreme Court's resolution of 573 tax cases on 24 September 2024. The measures are expected to significantly reduce the burden of tax litigation and
See MoreUS: IRS publishes guidance for tax-exempt bond issuers to claim refunds
The IRS published a guidance (Rev. Proc. 2024-37) for issuers of tax-exempt and other tax-advantaged bonds for claiming refunds of any overpayment of certain amounts paid to the US government on 18 September 2024. The guidance pertains to issuers
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Brazil updates reporting requirements for legal entities with tax benefits
Brazil published Normative Instruction No. 2.216 in the Official Gazette, on 5 September 2024, which updates and supersedes the annex of Normative Instruction No. 2.198 from 17 June 2024 (Declaration of Incentives, Waivers, Benefits, and Immunities
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Malta updates income tax deduction rules for capital expenditure on intellectual property
The government of Malta has issued a legal notice revising the local rule on deductions for capital expenditure related to intellectual property or intellectual property rights for income tax purposes on 13 September 2024. The provisions of these
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Russia extends foreign currency withdrawal restrictions
The Central Bank of Russia (CBR) has extended the restrictions on cash withdrawals of foreign currency for another six months, until 9 March 2025. The decision follows due to current sanctions against Russia which prevent domestic financial
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Poland issues goodwill depreciation guidelines
Poland’s Ministry of Finance issued a guidance, on 12 September 2024, clarifying that goodwill acquired through non-monetary means – such as acquiring a business by extinguishing a loan – cannot be depreciated for corporate income tax purposes
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Australia proposes draft law to simplify small business taxes, enhance foreign capital gains compliance
Australia’s government has proposed a new legislation to alleviate the administrative burden of tax processes for small businesses while enhancing capital gains withholding compliance for foreign residents. The draft legislation, ‘The
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