EU: European Parliament backs FASTER initiative
The European Parliament's plenary session adopted its opinion on 14 November 2024 after a consultation on the proposed Council Directive for the Faster and Safer Relief of Excess Withholding Taxes (FASTER). The opinion endorses the compromise
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Philippines streamlines tax treaty rules for government securities
The Philippines Bureau of the Treasury (BTr) announced in a press release on 5 November 2024 the implementation of a streamlined tax treaty procedure for non-resident investors in Government Securities (GS). This initiative is part of the
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Poland consults extension of temporary withholding tax exemption
Poland’s Ministry of Finance has initiated a public consultation regarding a draft regulation proposing the extension of the temporary exemption withholding tax under the “pay and refund” (MPR) mechanism until 31 December 2025, allowing
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Ireland: Lower House of Parliament passes Finance Bill 2024
The Irish lower house of parliament approved the Finance Bill 2024, which outlines major tax measures from Budget 2025 on Wednesday, 5 November 2024. Finance Bill 2024, which runs to 118 sections and over 200 pages, implements the taxation as
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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
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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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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Slovak Republic approves corporate tax and VAT rate changes, introduces financial transaction tax
The Slovak Republic government enacted a bill on 18 October 2024 to improve the state’s public finances by amending several tax measures and introducing a new financial transaction tax. Corporate tax rates The corporate tax rate has been
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Canada updates rules for paying non-residents for services
The Canada Revenue Agency (CRA) released an updated guide – T4A-NR – Payments to Non-Residents for Services Provided in Canada – for those who make payments to non-resident individuals, partnerships, or corporations for services rendered in
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Chile: Treaty allows reduced withholding tax rates for US residents
According to Oficio No. 1763/2024, a payer in Chile may refrain from withholding tax, or withhold tax at a reduced rate, on income paid to a US resident entity under the Chile-US income tax treaty. This applies only after the US recipient submits
See MoreUS: 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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Nigeria gazettes new withholding tax regime
Nigeria’s Federal Ministry of Finance has announced the Deduction of Tax at Source (Withholding) Regulations 2024 has been published in the official gazette on Wednesday 2 October 2024. The commencement date of the new Regulations is 30
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Czech Republic offers tax relief for individuals and businesses due to widespread flooding
The Czech Financial Administration announced several notices – providing information on tax payment deferments, penalty waivers, and various forms of tax relief – for citizens and businesses in light of the significant flooding on 18 September
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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
See MoreIreland: Tax appeals commission allows withholding tax deduction on dividends before 2019 Finance Act amendment
The Irish Tax Appeals Commission published a determination regarding the deduction of withholding tax on received foreign dividends on 10 September 2024. The particular issue that falls to be determined was whether foreign withholding taxes,
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Switzerland extends special rules on withholding tax for too-big-to-fail instruments
The Swiss Federal Council approved a temporary extension of the special rules on withholding tax for too-big-to-fail (TBTF) instruments to 31 December 2031. This ensures that banks can continue to obtain capital from within Switzerland on
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US: CRS reviews marginal effective tax rates on investment, expiring tax cuts
The Congressional Research Service (CRS) released a report (R48153) on 13 August 2024, examining tax rate differences by asset, sector, and source of finance. The report also evaluates the relative incentives for investment. The Tax Cuts and Jobs
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Australia: ATO releases withholding tax guidance for payments to non-residents
The Australian Taxation Office (ATO) has published guidance regarding withholding tax obligations related to specific payments made to non-residents on 1 August, 2024. The guidance provides clarification, ensuring taxpayers are aware of their
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