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
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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
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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
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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
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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
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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,
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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 MoreRussia: 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
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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
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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
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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 MoreTaiwan: 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
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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
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UN: Ad Hoc Committee on Framework Convention Discusses Substantive Elements
UN Resolution 78/230 of 22 December 2023 established an ad hoc intergovernmental committee to draft terms of reference for a UN framework convention on international tax cooperation. The first session of the ad hoc committee is being held between 26
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Australia proposes laws on interest limits, foreign investment fees, and taxation for general insurers
The Australian Parliament has recently approved the following bills, which are awaiting Royal Assent. The bills are as follows: The Treasury Laws Amendment (Making Multinationals Pay Their Fair Share—Integrity and Transparency) Bill of 2023
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Chile passes tax compliance bill with updated GAAR rules
On 10 April 2024, Chile's Chamber of Deputies passed the Tax Compliance Bill, which includes numerous tax measures aimed at improving tax compliance in Chile. The newly approved Bill also changes the Chilean tax code. The Senate must approve the
See MoreAustralia: ATO releases discussion paper on thin capitalization rules for foreign bank branches
On 17 April 2024, the Australian Taxation Office (ATO) published a discussion paper regarding the safe harbor formula for calculating the minimum capital requirements for inward investing deposit-taking institutions (ADIs) under the thin
See MoreAustralia offers additional guidance on new thin capitalization rules
On 8 April 2024, the Australian Taxation Office (ATO) declared additional consultations about the guidance for the new thin capitalization rules by the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share-Integrity and Transparency)
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