OECD: Further Reviews of Harmful Tax Practices
On 27 August 2024 the OECD released an update on the reviews by the Forum on Harmful Tax Practices of aspects of the tax regimes of some member countries of the Inclusive Framework under Action 5 of the project on base erosion and profit shifting
See More
Brazil plans to increase taxes to fund extended social contribution regime
Brazil’s Finance Minister Fernando Haddad has reportedly unveiled plans to raise levies on interest on equity and the social contribution on profits (CSLL). The tax hike is aimed to offset the costs associated with the partial extension of the
See More
Australia: Guidance on Thin Capitalisation Rules Published Online
Following the enactment of the new thin capitalisation laws in April 2024, the ATO has developed web guidance to assist taxpayers in applying the new rules, which are effective for income years commencing on or after 1 July 2023. Under the rules,
See MoreOECD: Report to the July Meeting of G20 Finance Ministers
On 25 July 2024 the OECD published the report prepared for the meeting of G20 Finance Ministers and Central Bank Governors held in Brazil from 25 to 26 July 2024. The report notes some recent developments in important areas of international tax
See More
Argentina removes five countries from non-cooperative jurisdictions list
Argentina has issued Decree 603/2024 of 10 July 2024, updating the list of non-cooperative jurisdictions for tax purposes as defined under Decree 862/2019. In this revised non-cooperative jurisdictions list, it removed Burkina Faso, Benin, Papua New
See More
Peru releases third version of high-risk tax schemes catalogue under GAAR
Peru tax authority (SUNAT) has published the third version of its catalogue of high tax risk schemes that could be challenged under the country's General Anti-Avoidance Rule (GAAR). This updated list includes 11 new high-risk schemes, bringing the
See More
Russia introduces tax reform draft laws
Russia's Ministry of Finance presented a set of draft laws to the Russian Government intended to enhance the tax system on 29 May, 2024. The package contains several major amendments to the Tax Code, Budget Code and Budget Law for 2024 and the
See More
Germany issues guidelines to combat tax havens
The German Ministry of Finance has released guidance on implementing the Tax Haven Defense Act, formerly the Act to Prevent Tax Avoidance and Unfair Tax Competition. This guidance introduces stringent measures to decrease business dealings with
See More
OECD: Definition of qualifying jurisdictions for application of Amount B of Pillar One
On 17 June 2024 the OECD Inclusive Framework on BEPS released supplementary elements relating to the report of 19 February 2024 on Amount B of Pillar One. Under the streamlined and simplified approach under Amount B, a pricing matrix is used to
See More
Taiwan publishes CFC rules for foreign residents
Taiwan's Ministry of Finance has released a notice regarding the application of Controlled Foreign Company (CFC) rules to foreign residents meeting the country's residency criteria. The notice states that foreign nationals, who lived in Taiwan
See More
France: Tax Authority updates interest deduction rates for shareholder loans
The French tax authority has updated the interest rates used to define the deductibility of interest payments made to shareholders. These updates are pertinent to companies with fiscal years ending between 31 December, 2023, and 29 June,
See More
Czech Republic updates non-cooperative jurisdictions list for CFC rules
The Czech Republic Ministry of Finance issued the Financial Bulletin No. 3/2024, on 28 February, 2024, which contains an updated notice regarding the list of non-cooperative jurisdictions concerning the Czech Republic's Controlled Foreign Company
See More
Russia: MoF clarifies tax exemption for CFC amid treaty suspensions
The Guidance Letter No. 03-12-11/2/11449, published by the Russian Ministry of Finance (MoF) on 12 February, 2024, addresses the tax exemption applicable to profits of Controlled Foreign Companies (CFCs) situated in jurisdictions with which Russia
See More
Australia publishes guidelines to address amendments to thin capitalisation rules
The Australian Taxation Office (ATO) published on Friday, 10 May, 2024, a list of priority public advice and guidance topics regarding the modifications to the thin capitalisation rules. Additionally, the ATO mentioned that it will update the
See More
Sweden considers new permanent residency rules for taxation
Sweden's Ministry of Finance announced, on 3 May, 2024, a significant update regarding permanent residency criteria for tax purposes. Following the release of a memorandum by the Tax Agency in November, 2023, proposing a redefinition of permanent
See More
Italy introduces CFC substitute tax measures
Italy’s Revenue Agency has published provisions for Controlled Foreign Company (CFC) substitute tax option, released as part of Legislative Decree No. 209 of 27 December 2023. Legislative Decree No. 209 outlines measures for adopting the Pillar
See More
Taiwan: Ministry of Finance relaxes taxation for CFC
The Ministry of Finance in Taiwan has released a notification regarding eased taxation regulations concerning profits from Controlled Foreign Corporations (CFCs) invested in enterprises situated in non-low-tax jurisdictions that are acknowledged
See More
UN: Ad Hoc Committee Discusses Issues for Early Protocols
Following an earlier Resolution on international tax cooperation and a report by the Secretary General setting out options going forward, UN Resolution 78/230 of 22 December 2023 established an ad hoc intergovernmental committee to draft terms of
See More