UN: High-Level Dialogue on Financing for Development
On 20 September 2023 the UN held a high-level dialogue on financing for development, including a session on Promoting inclusive and effective international tax cooperation and mobilizing domestic resources. Keynote addresses were given by the
See MoreG20 Leaders’ Declaration
The Declaration issued by the G20 leaders at their meeting on 9 and 10 September 2023 included the following points: Global Economic Situation The Declaration noted the recent global crises that have posed challenges to long-term growth and
See More
OECD: Report to the G20 leaders meeting of September 2023
The tax report by the OECD Secretary General to the meeting of G20 leaders on 9 to 10 September 2023 outlines the latest international tax developments in international tax reform, including the work on the two-pillar international tax plan;
See More
Russia amends regulations on taxation of controlled foreign companies
On 31 August 2023, the government of Russia announced new tax rules that will exempt profits of foreign collective investment structures from taxation. The exemption will apply if the following conditions are met: The profit of the structure is
See More
Germany: BMF publishes draft guidance on CFC legislation
On 20 July 2023, the Federal Ministry of Finance (BMF) issued draft guidance concerning the implementation of the Foreign Transactions Tax Act (FTTA), specifically addressing the taxation aspects related to controlled foreign corporations (CFCs).
See More
OECD: Facilitating the Use of Treaty Exchanged Information for Non-Tax Purposes
Sharing of treaty-exchanged information with relevant law enforcement agencies for non-tax purposes helps to combat illicit financial flows (IFFs), money laundering and corruption. Institutions often face operational challenges in implementing this
See More
OECD: Subject to Tax Rule
On 17 July 2023 the OECD published details of the subject to tax rule (STTR) developed by the Inclusive Framework on BEPS as part of Pillar Two of the two-pillar proposals on international tax. The STTR gives jurisdictions the right to “tax
See More
OECD: Template for GloBE Information Return
On 17 July 2023 the OECD published details of the contents of the GloBE information return (GIR) under Pillar Two. The GIR is designed to collect the information needed by the tax administration to arrive at an appropriate risk assessment and to
See More
OECD: Outcome Statement on the Two Pillar Solution
On 11 July 2023 an Outcome Statement on the two-pillar international tax solution was approved by 138 member jurisdictions of the Inclusive Framework on base erosion and profit shifting. The Outcome Statement summarises the package of deliverables
See More
OECD Report to the G20 Financial Ministers and Central Bank Governors
On 17 July 2023 the OECD published the report prepared for the meeting of G20 finance ministers and central bank governors held in India on 17 and 18 July 2023. Update on the Two-Pillar International Tax Solution The report noted that on 11
See More
OECD: Consultation on Amount B of Pillar One
On 17 July 2023 the Inclusive Framework issued a consultation document asking for stakeholder input on Amount B under Pillar One. Comments are invited by 1 September 2023. Amount B applies to baseline marketing and distribution activities, which
See More
OECD Tax Talk Outlines Progress on Two Pillar Proposals
An OECD Tax Talk held on 19 July 2023 summarised recent developments on the two-pillar international tax proposals. Pillar One – MLC The implementation of Pillar One will require a multilateral convention (MLC) to ensure that the
See More
US: IRS publishes practice units on interest expense limitations
On 16 May 2023, the IRS Large Business and International (LB&I) division issued two practice units in relation to interest expense limitations for related party loans. Interest Expense Limitation on Related Foreign Party Loans Under IRC
See More
OECD: Tax Transparency In Latin America 2023
On 27 June 2023 the OECD published Tax Transparency in Latin America 2023, during the latest meeting of the Punta del Este initiative. The Punta del Este Declaration aimed to tackle tax evasion and avoidance and other financial crimes by promoting
See More
Uganda: Minister of Finance presents Budget for 2023/2024 to the Parliament
On June 15, 2023, the Ugandan Minister of Finance, Planning, and Economic Development, Mr. Matia Kasaija, presented the budget for financial year 2023/2024 to the Parliament. On that day, Income Tax (Amendment) Bill 2023 was also passed which was
See More
UK: Second Reading of Spring Finance Bill 2023
On 13 June 2023 the UK government published the Tax Information and Impact Notes for government amendments at the report stage of the Spring Finance Bill 2023. The Bill includes the following measures: Multinational Top-up tax: UK adoption of
See More
UAE clarifies interest deduction rules
On 23 May 2023, the United Arab Emirates (UAE) Ministry of Finance (MoF) published Decision No. 126 of 2023 on the general rules for limiting the deduction of interest for corporate tax purposes. To determine the deductible interest from taxable
See More
IMF: Mining Revenues and Inclusive Development in Guinea
An IMF working paper on Mining Revenues and Inclusive Development in Guinea by A. Badel and R.F. Lyngaas was published on 29 April 2023. The working paper looked at the potential benefits from increasing the taxation of the foreign extractive
See More