Ukraine mandates reporting of controlled foreign companies (CFCs)
On 6 February 2024, the State Tax Service of Ukraine issued a release outlining the mandatory reporting of controlled foreign companies. The State Tax Service of Ukraine informs that the campaign for submission by controlling persons of Reports on
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Australia: ATO deliberating on amended interest limitation rules
On 30 January 2024, the Australian Taxation Office (ATO) announced that it is seeking public input and feedback on guidance and advice related to the amendments to the interest deduction limitation rules, also known as thin capitalization rules.
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OECD releases ICAP statistics
On 29 January 2024 the OECD released the first aggregated statistics from the Forum on Tax Administration’s International Compliance Assurance Programme (ICAP). ICAP The ICAP is a voluntary risk assessment and assurance program whose
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UK: Transfer Pricing and Diverted Profits Tax Statistics
On 25 January 2024 HMRC published the latest set of statistics relating to transfer pricing and the diverted profits tax. The latest release contains data up to end of the 2022/23 tax year. The transfer pricing work is an important part of
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OECD: Update of Estimated Revenue Gains from Pillar Two
On 9 January 2024 the OECD held a webinar to introduce the updated assessment of the projected economic impact of the global minimum tax under Pillar Two of the two pillar solution to international tax. The OECD has used improved methodology and
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Russia: FTS updates list of jurisdictions that do not exchange proper information for CFC purpose
On 10 January 2024, the Russian Federal Tax Service (FTS) published updated list of jurisdictions that do not exchange tax information with Russia (Decree No. ЕD-7-17/914). The list pertains to the tax exemption for profits of controlled foreign
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Belgium approves 2024 budget Introducing new CFC rules
Belgium has approved the 2024 budgetary measures, including new CFC rules, increased progressive tax on credit institutions, and strengthening Cayman tax rules. New CFC rules One key aspect of Belgiam’s CFC rules is the implementation of the
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Greece: AADE issues preferential tax regime jurisdictions list for tax year 2022
On 27 December 2023, the Greek tax authority (AADE) released Circular No. A.1205, outlining which jurisdictions qualify as preferential tax regimes for the 2022 tax period. The list comprises nations where the corporate income tax and capital gains
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Lithuania updates its blacklist in various tax aspects
On 30 November 2023, Lithuania issued an order revising its list of selected territories (blacklist), incorporating Russia as a new addition. The blacklist plays a crucial role in various tax aspects, including Lithuania's CFC rules. List of
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Germany updates tax haven defense ordinance: Adds and removes jurisdictions in response to EU decision
On 20 December 2023, Germany issued the Ordinance, amending the Tax Haven Defense Ordinance, as published in the Official Gazette. The Tax Haven Defense Ordinance plays a critical role in identifying jurisdictions considered non-cooperative under
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Armenia: Central bank lowers refinancing interest rate
On 12 December 2023, the Armenian Central Bank announced that it lowered the refinancing interest rate from 9.5% to 9.25%. This is the fifth interest rate reduction for 2023. The previously reduced refinancing interest rates are as follows:
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Argentina issuing bonds for state reconstruction
On 22 December 2023, the Argentine government issued Decree No. 72/2023 concerning the Bonds for the Reconstruction for a Free Argentina or Bonos para la Reconstruccion de una Argentina Libre (BOPREAL). The Argentine Central Bank will issue BOPREAL
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Cyprus: Special contribution for defence on interest reduced to 17%
Cyprus has decreased the Special Contribution for Defence rate on interest from 30% to 17%, which will be effective from 1 January 2024. This contribution rate is applicable to all individuals and companies receiving or credited with interest. The
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Italy: CFC rules related to GloBE pillar 2 amended to include 15% tax rate option and substitute tax
On 19 December 2023, Italy's Council of Ministers passed a legislative decree to enforce the tax reforms related to international taxation. This includes implementing the Pillar 2 global minimum tax under Council Directive (EU) 2022/2523 of 14
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Belgium proposes new draft law for CFC rules
The Belgian government has submitted a new draft bill to parliament for implementing stricter rules concerning the taxation of the undistributed income of a controlled foreign company (CFC), shifting from model B (targeting tax avoidance
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Brazil proposes to modify interest on net equity for 2024
On 30 November 2023 and 5 December 2023, Brazil’s Valor Econômico newspaper published a report stating that the Ministry of Finance of Brazil has completed the draft of a new proposal to amend the Interest on Net Equity (INE) mechanism. The
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Germany: MOF issues draft guidance on anti-tax avoidance measures
On 30 November 2023, the German Ministry of Finance (MoF) issued draft guidance on anti-tax avoidance measures targeting non-cooperative jurisdictions. This follows the 2021 Tax Haven Defense Act, responding to EU guidelines against harmful tax
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UN Adopts Resolution to Set Up a Framework Convention on Tax
On 22 November 2023 the UN general assembly adopted a resolution to commence the process of setting up a framework convention on tax. The framework convention could ensure that the UN is the main body for decision-making on international tax
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