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
See MoreAustralia 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
See MoreOECD: 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
See MoreOECD: 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
See MoreOECD: 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
See MoreOECD: 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
See MoreOECD: 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
See MoreOECD: 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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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
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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
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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
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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
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