UN Tax Committee: Transfer Pricing Issues
On 16 October 2024 the UN Tax Committee discussed transfer pricing issues. The transfer pricing subcommittee presented for approval a paper on dispute resolution addressing the implementation of advance pricing agreement (APA) programs. The
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El Salvador releases tax havens lists for 2025
El Salvador's Ministry of Finance released the updated General Guide on preferential tax regimes (tax havens) on 27 September 2024, detailing jurisdictions and territories considered tax havens for the 2025 fiscal year, including low and no-tax
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Australia: ATO consults new restructuring, thin capitalisation, debt deduction creation rules
The Australian Taxation Office (ATO) launched a public consultation on Practical Compliance Guideline (PCG) 2024/D3 - Restructures and the new thin capitalisation and debt deduction creation rules on 9 October 2024. The ATO has published the
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Chile: Parliament passes tax compliance bill
Chile’s Chamber of Deputies have passed the Tax Compliance Bill (Proyecto de Ley de Cumplimiento de las Obligaciones Tributarias). Earlier, Chile’s Senate approved the Tax Compliance Bill on 24 September 2024 which included key changes to
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Taiwan introduces CFC De minimis rule for profit seeking enterprises
Taiwan's Ministry of Finance has announced a de minimis test enabling profit-seeking enterprises to avoid recognizing investment income under the CFC Rules on September 2024. The National Taxation Bureau of the Southern Area, Ministry of Finance
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France sets interest deductibility rate limit for shareholder payments
France’s Ministry of Finance released the quarterly TMP (taux moyen pratiqué) rate to determine the annual market rate limit for deducting interest paid to shareholders. French law allows corporations to deduct annual shareholder interest
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Ireland named amongst top 10 tax havens globally
According to the Tax Justice Network's latest ranking report published on 1 October 2024, Ireland has surpassed the Bahamas to become the ninth-largest tax haven in the world. A spokesperson for Ireland's Department of Finance has denied that the
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Chile passes tax compliance bill with income, VAT, transfer pricing measures
Chile’s Senate has approved the Tax Compliance Bill on 24 September 2024, which will be presented to the Lower House for final approval. The newly approved tax measures include modifications to the general anti-avoidance rule (GAAR), statute of
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Australia: ATO publishes guidance on approved forms for thin capitalisation tests
The Australian Taxation Office has issued guidance regarding the approved form that allows taxpayers to choose between the group ratio test and the third-party debt test. This form is used when making a choice to apply the group ratio test or
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Australia endorses OECD subject to tax rule for multinational tax reform
Andrew Leigh, the Australian Assistant Minister for Competition, Charities, and Treasury, announced that Australia is committed to multinational tax reform through a Statement of Support for the OECD's 'Subject to Tax Rule' on 20 September
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Russia updates list of jurisdictions without adequate information exchange for CFC purposes
The Russian Federal Tax Service is in the process of completing a draft order that will update the list of jurisdictions lacking sufficient tax information exchange with Russia. This new list will supersede the Order No. ED-7-17/914 @ of 1 December
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OECD: Report on Simplified Peer Review of Egypt under BEPS Action 14
On 16 September 2024 the OECD published the simplified peer review report on Egypt under Action 14 of the project on base erosion and profit shifting (BEPS). The report sets out the results of Stage 1 of the simplified peer review of the
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OECD: Report on Simplified Peer Review of Nigeria under BEPS Action 14
On 16 September 2024 the OECD published the simplified peer review report on Nigeria under Action 14 of the project on base erosion and profit shifting (BEPS). The report sets out the results of Stage 1 of the simplified peer review of the
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OECD: Report on Simplified Peer Review of Costa Rica under BEPS Action 14
On 16 September 2024 the OECD published the simplified peer review report on Costa Rica under Action 14 of the project on base erosion and profit shifting (BEPS). Members of the OECD Inclusive Framework have committed to implementing the minimum
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OECD: Report on Simplified Peer Review of Colombia under BEPS Action 14
On 16 September 2024 the OECD published the simplified peer review report on Colombia under Action 14 of the project on base erosion and profit shifting (BEPS). Under BEPS Action 14, members of the OECD Inclusive Framework have committed to
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OECD: Report on Simplified Peer Review of Lithuania under BEPS Action 14
On 16 September 2024 the simplified peer review report on Lithuania was issued under Action 14 of the project on base erosion and profit shifting (BEPS). Members of the OECD Inclusive Framework have committed to implementing the minimum standard
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Armenia lowers Central Bank refinancing interest rate
Armenia’s Central Bank has lowered the refinancing interest rate from 7.75% to 7.50%. This marks the sixth rate reduction in 2024, following a previous drop of 9.25%. The Central Bank's refinancing rate influences the deductible interest on
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OECD: Report on Simplified Peer Review of Serbia under BEPS Action 14
Under Action 14 of the OECD project on base erosion and profit shifting (BEPS), members of the OECD Inclusive Framework have committed to implementing the minimum standard on strengthening the effectiveness and efficiency of dispute resolution
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