Belgium publishes guidance on new CFC rules
Belgium’s tax authorities have issued two circular letters - Circular 2024/C/82 and Circular 2024/C/83 - on 13 December 2024 - providing clarity on specific aspects of the controlled foreign company (CFC) rules introduced in 2023. The amended
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Austria updates CFC rules to prevent double taxation under Pillar Two
Austria's parliament has amended its CFC rules to avoid double taxation issues under the Pillar Two global minimum tax framework. Amendments to Section 10a of the Austrian Corporate Income Tax Act have been approved and now require Qualified
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Slovenia proposes changes corporate income tax law
Slovenia's government has presented a draft bill (EVA: 2024-1611-0039) to the parliament on 25 October 2024, proposing several amendments to the corporate income tax law. Tax loss carry-forward limitation The bill suggests limiting the
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New Zealand introduces tax policy work programme
New Zealand’s Minister of Revenue has introduced a tax policy work programme on 13 November 2024, which aims to simplify tax and reduce compliance costs, address integrity risks, and improve fiscal sustainability to rebuild the economy. The
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Philippines streamlines tax treaty rules for government securities
The Philippines Bureau of the Treasury (BTr) announced in a press release on 5 November 2024 the implementation of a streamlined tax treaty procedure for non-resident investors in Government Securities (GS). This initiative is part of the
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Colombia: DIAN mandates certification for third-party debts under thin capitalization rules
The Colombian tax authority (DIAN) issued Ruling 803 of 23 September 2024, released on 1 November 2024, which provides guidance on the necessary certification of third-party debts for interest deduction purposes under the thin capitalization
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Czech Republic updates list of non-cooperative CFC jurisdictions
The Czech Republic Ministry of Finance has released Financial Bulletin No. 9/2024, containing a notice regarding the lists of non-cooperative jurisdictions for various periods about the Czech Republic's controlled foreign company (CFC)
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Australia: ATO issues guidance on thin capitalisation rules, related provisions
The Australian Taxation Office (ATO) released guidance on 3 November 2024, outlining how the thin capitalisation rules interact with other provisions. The thin capitalisation rules limit the amount of debt deductions you can claim. Regard must
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US: IRS and Treasury Plan to Issue Guidance on Streamlined Approach to Baseline Distribution Activities
In the IRS and Treasury Priority Guidance Plan for 2024/25, issued on 3 October 2024, there is a plan for a new section 482 guidance project to provide guidance for taxpayers consistent with Amount B of Pillar One. The OECD Amount B Guidance
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US: IRS clarifies CFC not eligible for dividends received deduction under section 245A
The US Internal Revenue Service (IRS) issued an Office of Chief Counsel memorandum clarifying that a controlled foreign corporation (CFC) is not eligible for a dividends received deduction under section 245A. This memorandum provides
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Chile updates tax compliance law, introduces changes to GAAR, transfer pricing, and CFC
Chile's Internal Revenue Service (SII) has announced that the Law on Compliance with Tax Obligations (Law No. 21.713) has been published in the Official Gazette on 24 October 2024. General and Special Anti-Avoidance Rules changes The General
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US: Congressional Research Service reviews mortgage interest deduction
The Congressional Research Service (CRS) released the In Focus report (IF 12789 ) at the US Library of Congress on 22 October 2024. This report analysed the mortgage interest deduction, highlighting policy options that Congress may
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UN: Resolution on Negotiating Committee for Framework Convention for International Tax Cooperation
On 14 October 2024 a Resolution was drafted by Nigeria on behalf of the Africa group at the UN, to adopt the terms of reference for the UN Framework Convention on International Tax Cooperation. The draft Resolution referred to the work of the Ad Hoc
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Latvia updates list of tax havens, removes Antigua and Barbuda
Latvia announced an updated list of low-tax and tax-free jurisdictions in the Official Gazette on 23 October 2024. This list, derived from the latest EU list of non-cooperative jurisdictions, notes the removal of Antigua and Barbuda, effective 1
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UN Tax Committee: Tax, Trade and Investment Agreements
On 17 October the UN Tax Committee discussed issues around the interaction of tax, trade and investment agreements. Guidance on tax and investment agreements Following the presentation of draft guidance on the relationship of tax and
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UN Tax Committee: Issues in Extractive Industries Taxation
On 15 October 2024 the UN Tax Committee discussed developments in their work on extractive industries taxation. The work of the relevant subcommittee has focused on the energy transition; the valuation of mining products for tax purposes; and tax
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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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