Chile passes tax compliance bill with updated GAAR rules
On 10 April 2024, Chile's Chamber of Deputies passed the Tax Compliance Bill, which includes numerous tax measures aimed at improving tax compliance in Chile. The newly approved Bill also changes the Chilean tax code. The Senate must approve the
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South Africa: SARS releases tax court judgment clarifying arm’s length principle regarding royalty payments
On 6 March 2024, the South African Revenue Service (SARS) published online the tax court Judgment concerning Case No. IT 14302, providing clarification on how the arm’s length principle is applied in transactions involving related parties. The
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Portugal: Central administrative Court upholds deductions for payments to low-tax jurisdictions
On 11 January 2024, the Central Administrative Court of the Southern Region in Portugal made a decision regarding the deductibility of payments made to jurisdictions with low tax rates. The case involved a major company providing aircraft
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UK: HMRC announces public consultation on draft guidance on new rules for R&D tax reliefs
On 9 February 2024, the UK HMRC announced the public consultation on the draft guidance, which provides modifications to the Research and Development (R&D) tax reliefs that are expected to be implemented on 1 April 2024. The deadline for
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Hong Kong offers tax deductions for mobile network operators on spectrum utilization fees
On 19 January 2024, the Hong Kong Inland Revenue Department declared the Inland Revenue (Amendment) (Tax Deductions for Spectrum Utilization Fees) Ordinance 2024. This ruling has been published in the Official Gazette and introduces tax deductions
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Philippines: BIR clarifies withholding tax made by online payment platforms
On 15 January 2024, the Philippines Bureau of Internal Revenue (BIR) published the Revenue Memorandum Circular No. 8-2024 of 15 January 2023, in which it clarified the imposition of the new 1% withholding tax for payments by online platforms to
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Argentina: National congress mulls new Incentive regime for major investments
The Argentine National Congress is evaluating a draft legislation to establish a new incentive regime for major investments by sole purpose vehicles in specific sectors. The sole purpose vehicles for the new incentive regime include corporations,
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Philippines imposes withholding tax on online platform payments
On 29 December 2023, the Philippine News Agency (PNA) published a release declaring that the Bureau of Internal Revenue (BIR) had imposed a 1% withholding tax on online merchants with earnings amounting to more than PHP 500,000 annually. BIR
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Kazakhstan announces amendments to its tax laws
On 12 December 2023, Kazakhstan published Law No. 45-VIII of 12 December 2023 in the Official Gazette, providing various amendments to its tax laws including digital assets. The key amendments are as follows: The amendment of the new limit on
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Irish revenue issued new guidance on interest limitation rules and foreign currencies
On 10 January 2024, the Irish Revenue released eBrief No. 014/24, which includes updated guidance (TDM 35D-01-01) related to the interest limitation rule (ILR). In accordance with Article 4 of ATAD, the ILR limits the interest deductibility of
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Canada: Consultation on Strengthening the General Anti-Avoidance Rule
On 9 August 2022 the Canadian government published a consultation paper on strengthening the general anti-avoidance rule (GAAR). Comments are invited by 30 September 2022. The paper notes that the GAAR, which was first introduced in 1988, has
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UK: Delay in Payment of R&D Tax Credits
It was reported on 17 May 2022 that HMRC has suspended payment of some research and development tax relief claims because it is investigating irregularities. Most R&D tax credit claims will not be affected but some irregular claims are being
See MoreEU: European Commission Proposes Tax Allowance for Equity
On 11 May 2022 the European Commission put forward proposals for a tax allowance that would reduce the current tax advantage for debt over equity. This allowance would be designed to encourage businesses to access more equity financing and reduce
See MoreFrance: Supreme Court decides on the definition of residents for tax treaty purposes
On 2 February 2022, the French Administrative Supreme Court ruled that a company benefiting from a temporary and partial corporate income tax exemption should be considered liable to tax and therefore a tax treaty resident. The French tax
See MoreIMF report on Israel’s economy recommends tax changes
On 7 February 2022 the IMF published a report on Israel’s economy following discussions under Article IV of the IMF’s articles of agreement. The IMF notes that Israel managed the pandemic well, providing effective government support to the
See MoreUK: LOB Clause of US-UK treaty does not restrict unilateral foreign tax credit
Aozora GMAC Investments Limited, resident in the UK, was a subsidiary of a Japanese bank. The taxpayer made a loan to its subsidiaries in the US. Article 11(1) of the US-UK double tax treaty provided for exclusive taxation of the interest income
See MoreSingapore enacts Income Tax (Amendment) Act 2021
On 16 November 2021, the Income Tax (Amendment) Act 2021 came into force. The Act gives effect to 2021 Budget and non-Budget tax measures, including an extension of the enhanced loss carry-back relief scheme, enhanced deduction for donations and
See MoreItaly: New patent box regime uses a cost-based approach
On 15 October 2021 a law decree introduced new rules for the patent box regime. The new rules grant an extra deduction of certain research and development (R&D) costs incurred by Italian taxpayers, including expenses relating to
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