Australia initiates consultation for improving foreign resident capital gains withholding tax
The Australian Treasury launched a public consultation on improving the foreign resident capital gains withholding tax regime on 23 July, 2024. The consultation is set to conclude on 5 August, 2024. As part of the 2023–24 Mid-Year Economic and
See More
US: Missouri to let pass-through entities bypass entity-level tax
The state of Missouri announced that it will permit members of pass-through entities (PTEs) to opt out of the elective entity-level tax under HB 1912, which was signed by Governor Mike Parson (R) on 10 July, 2024. The HB 1912 will take effect on
See More
Portugal approves tax measures to boost economy, includes reduced CIT rate and VAT groups
The Portuguese government approved a comprehensive set of tax proposals during the Council of Ministers meeting, on 4 July 2024, to promote the scale of Portuguese companies, consolidation and capitalisation; develop new financing and streamline
See More
Hong Kong gazettes patent box regime
The Hong Kong Inland Revenue Department (IRD) announced the issuance of the Inland Revenue (Amendment) (Tax Concessions for Intellectual Property Income) Ordinance 2024 in the Official Gazette on 5 July 2024. One of the main aspects of the
See More
Hong Kong approves patent box tax concession
The Hong Kong SAR (HKSAR) Legislative Council passed the draft legislation (Inland Revenue (Amendment) (Tax Concessions for Intellectual Property Income) Bill 2024) on the patent box tax incentive regime on 26 June, 2024. The draft bill proposes
See More
Australia: ATO issues notice on withholding tax rules for interest, dividend, or royalty payments to non-residents
The Australian Taxation Office (ATO) released a notice regarding the withholding tax requirements for making interest, dividend, or royalty payments to non-residents on Sunday, 19 May, 2024. Taxpayers who have paid interest, dividends, or
See More
Norway initiates consultation on 12-month deadline for tax deduction on unrecoverable receivables
Norway's Ministry of Finance has initiated a public consultation regarding the proposed introduction of a 12-month time limit for tax deductions for companies on unrecoverable trade receivables from related parties. A corresponding time limit is
See More
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
See MoreHong Kong: Draft legislation for patent box regime announced
On 28 March 2024, the Hong Kong Inland Revenue Department published the Inland Revenue (Amendment) (Tax Concessions for Intellectual Property Income) Bill 2024 in the Gazette to implement the "patent box" tax incentive. The draft bill proposes a
See More
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
See MorePortugal: 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
See More
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
See MoreHong 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
See More
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
See More
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,
See MorePhilippines 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
See More
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
See More
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
See More